UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUL I 1993
OFFICfe-OF
SOLID WASTE AND EMEflGtNCV RESPONSE
MEMORANDUM
SUBJECT: aent
Enclosed is the report titled "Integrating Removal and
Remedial Assessments Under the Superfund Accelerated Cleanup
Model."
The report describes removal assessment and remedial site
assessment in various Regions and focuses on issues-'involved in
integrating these activities. The study covers data collection,
sampling, and analytical requirements of screening assessments.
It also examines the site evaluation process from site discovery
to evaluation of criteria for a removal action or proposal to the
National Priorities List (NPL).
The report was developed in order to establish a baseline of
current approaches to removal and remedial assessment activities
and address the application of these approaches under the
Superfund Accelerated Cleanup Model. It was also developed to
further cross-program understanding between the removal and
remedial programs. The report should be used as a reference in
developing integrated assessments.
TO:
FROM:
Site Assessment Section Chiefs
Removal Managers,
Regions I - X
Attachment
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INTEGRATING REMOVAL AND REMEDIAL
ASSESSMENTS UNDER THE
SUPERFUND ACCELERATED CLEANUP MODEL
June 1993
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CONTENTS
Page
1.0 INTRODUCnON 1
2.0 STATUTORY FRAMEWORK AND REGULATORY DEFINITIONS 3
2.1 Notification and Discovery 3
2.2 Removal and Remedial Assessment Objectives 5
2.2.1 Preliminary Assessment 5
222 Site Inspection 9
2.3 Superfund Response Actions 11
2.3.1 Removal Action 12
232 Remedial Action 13
3.0 COMPARISON OF ASSESSMENT ACTIVITIES 15
3.1 Cross-Program Site Referral 15
3.2 Sampling Decisions 17
3.3 Removal and Remedial Assessment Activities 17
3.4 Event Tracking and Response Reporting 21
3.4.1 CERCUS 22
3.4.2 ERNS 22
3.4.3 SCAP and STARS Targets and Measures : . 22
3.5 Contractor Support 23
3.6 Analytical Quality Assurance Requirements 24
3.6.1 Use of Non-CLP Laboratories 25
3.6.2 Analytical Costs 25
3.63 Data Integration 26
4.0 REGIONAL ISSUES 31
4.1 Comparison of Regional Reports 31
4.2 Review of Regional Surveys 32
4.2.1 Removal Action Criteria in Remedial Site Assessments 33
4.2.2 HRS Criteria in Removal Assessments 33
4.23 Removal Assessment Activities 36
4.2.4 Health Assessment and Risk Assessment 37
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FIGURES AND TABLES
Page
Figure 1. Traditional Assessment Processes 4
Table 1. Removal and Remedial Assessment Objectives 6
Table 2. Sampling Decisions 18
Table 3. Activities Common to Both Removal and Remedial Assessments 19
Table 4. Activities Unique to Removal Assessments 20
Table 5. Activities Unique to Remedial Assessments 20
Table 6. Analytical QA Requirements 27
Table 7. Data Requirements for Removal and Remedial
(Site Assessment) Programs 30
Table 8. Removal Action Criteria in Remedial Site Assessments 34
Table 9. Remedial HRS/NPL Criteria in Removal Assessments 35
Table 10. Removal Assessment Analyses and Costs 40
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1.0 INTRODUCTION
This study examines data collection, sampling, and analytical requirements of screening
assessments currently performed by the Superfund removal and remedial programs. It
reviews the site evaluation process from site discovery through evaluation of criteria for a
removal action or proposal to the National Priorities List (NPL). It also examines
Regional assessment practices, including how removal program data can support
remedial site assessment objectives, and vice versa. The study compares and contrasts
selected elements of the Superfund removal and remedial programs, focusing on issues
involved in integrating assessment activities under the Superfund Accelerated Cleanup
Model (SACM).
SACM streamlines and accelerates the Superfund program SACM is designed to deliver
quicker results, including reduction of immediate health risks at all sites and restoration
of the environment over the long term.
SACM integrates removal and remedial actions where appropriate, while maintaining
separate legal authorities for the two programs, whose specific applications at Superfund
sites will be different but complementary (OSWER Directive 9203.1-01, April 7, 1992).
For example, instead of separate removal and remedial preliminary assessments (PAs),
EPA can perform a combined remedial and removal assessment at the beginning of the
site evaluation process. A Regional Decision Team (RDT) will review assessment
results to decide whether early action is needed to reduce immediate risk to the public
and the environment and whether long-term cleanup should be initiated to restore the
environment. Enforcement, community relations, and public participation activities will
occur throughout the process. With ,SACM, EPA can achieve immediate risk reduction
at a greater number of sites, conduct clean-up efforts more efficiently, prioritize
resources to fund more cleanups, and eliminate redundant assessment-activities.
To support SACM implementation, this study describes the site assessment stages of the
removal and remedial programs under current guidelines to evaluate the potential for
integrating activities. The study reviewed national and Regional guidance documents to
identify field data objectives common to both programs, assessment information and
sample analysis requirements, and field practices. The study also reviewed program-
specific training and qualifications requirements, examined a small sample of removal
and remedial assessment reports, and surveyed Regional removal program personnel to
determine if activities under one program satisfied requirements of the other.
The results of the study support the concept that SACM implementation would increase
efficiency and accelerate the Superfund process within the framework of the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP),
while ensuring that cleanups continue to be protective and allow for appropriate public
involvement.
The NCP (40 CFR Part 300) allows for the coordination of combined site screening
assessments. Section 400.315(c) of the NCP states, "Removal actions shall, to the extent
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practicable, contribute to the efficient performance of any anticipated long-term remedial
action with respect to the release concerned," setting the regulatory framework for
increased coordination between the removal and remedial programs. Screening
assessment activities lend themselves to program integration, since these activities vary
little between the removal and remedial programs.
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2.0
STATUTORY FRAMEWORK AND REGULATORY DEFINITIONS
Section 105 of CERCLA, as amended by the Superfund Amendments and
Reauthorization Act (SARA) and section 311 (c)(2) of the Clean Water Act (CWA),
required development of the NCP to specify the statutory requirements to implement
Superfund. NCP Subpart E—Hazardous Substances Response (section 300.400) addresses
site evaluations from discovery or notification through cleanup:
(a) This subpart establishes methods and criteria for determining the
appropriate extent of response authorized by CERCLA: (1) When there is
a release of a hazardous substance into the environment; or (2) When there
is a release into the environment of any pollutant or contaminant that may
present an imminent and substantial danger to the public health or welfare.
The Office of Solid Waste and Emergency Response (OSWER) and the Office of
General Counsel (OGC) determined that the NCP offers adequate flexibility to deal with
different types of clean-up actions as proposed by SACM. No statutory changes will be
made to accommodate SACM, and SACM does not provide independent authority to
perform actions not authorized by CERCLA and the NCP. Any action taken under
SACM must still fall into the category of either a removal or remedial action (OSWER
Directive 9203.1-03, July 7, 1992).
Figure 1 shows traditional removal and remedial assessment activities prior to SACM.
The diagrams do not indicate time schedules. Removal assessments determine the need
and type of short-term or emergency response actions to protect human health and the
environment, while remedial activities address long-term remediation.
2.1 Notification and Discoveiy
NCP section 300.405 describes the most common ways EPA learns of releases, including
CERCLA sections 103(a) (reportable quantities) and 103(c) (notification of the
transport, storage, and disposal of hazardous substances) reports, government
investigation, notification by a permit holder, government or public inventories, citizen
petitions, federal facility requests, and reports to the National Response Center (NRC).
The NRC, established by the CWA and operated by the U.S. Coast Guard (USCG), is
the U.S. government's 24-hour emergency notification center. When hazardous waste
releases and oil spills are reported by telephone, the NRC collects the information,
including the location of the release, estimated quantity of material released, party
responsible for release, possible source of release, and date and time of the release. The
NRC then promptly notifies the appropriate EPA Regional office or USCG district for
releases to navigable waters.
When EPA receives notifications to Superfund other than through, the NRC, it refers
them to either the removal or the remedial program. Current Regional referral practices
vary and no national guidance exists. To eliminate this variable referral, SACM
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FIGURE 1: TRADITIONAL ASSESSMENT PROCESSES
REMOVAL PROGRAM
REMEDIAL PROGRAM
Removal Actions May Occur at any Stage
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proposes that all discoveries be routed and tracked through "one door," with the NRC
continuing as a 24-hour notification mechanism for emergencies.
To report a non-emergency abandoned waste site or another type of potential release,
citizens may use the remedial program's PA petition (OERR Publication 9200.5-301FS)
to notify EPA and thereby trigger a CERCLA site discovery. The remedial program
adds the site to its inventory and schedules the assessment within 12 months of
notification. If at any time the remedial program identifies a possible need for
emergency response or potential removal action, it promptly notifies the removal
program for timely coordination.
22 Removal and Remedial Assessment Objectives
Table 1 gives an overview of common removal and remedial assessment objectives. The
goal of a removal assessment is to determine hazard conditions at a site and whether
those conditions meet the NCP criteria for a removal action. Generally, the most critical
aspect is to identify immediate threats to the population and the environment by
establishing whether hazardous substances are present on site and the potential for their
release.
The goal of remedial site assessments is to identify the highest priority sites for long-term
remediation. The Hazard Ranking System (HRS) specifies criteria to be used during
remedial assessments to identify these sites.
22.1 Preliminary Assessment
Both the removal and remedial programs conduct a PA to determine appropriate
Superfund response actions. The PA identifies hazardous substance releases and human
and environmental populations that might be affected by a site. If a PA concludes that
the site warrants further investigation to evaluate clean-up options, a site inspection (SI)
follows in both programs.
Removal program practices vary Regionally. Most Regions perform removal assessments
of variable scope incorporating both PA and SI components. The primary removal
assessment objective is to determine the need for and urgency of a removal action. At
any release where the EPA On-Scene Coordinator (OSC) determines there is a threat to
public health, welfare, or the environment, the OSC may take actions to abate, minimize,
stabilize, mitigate, or eliminate the threat. Site assessment activities in the remedial
program—previously known as "pre-remedial" activities—include PAs as specified in the
NCP for every site in CERCLIS (the CERCLA information system inventory of
uncontrolled hazardous waste sites). Remedial site assessments characterize threats
posed by sites and identify the nation's highest long-term remediation priorities. The
primary objective of remedial site assessments is to collect data to evaluate sites
according to the HRS and identify those that should be on the NPL for long-term
remediation.
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Table 1
Removal and Remedial Assessment Objectives
Objective
Removal
Remedial
Determine need for further action; screen out sites that pose no
significant threat; refer-sites to another program
X
X
Set priority for sampling inspection
X
X
Establish priorities among sites
X
X
Collect data to evaluate NPL eligibility
X
Identify presence and immediacy of threat
X
X
Characterize site for more effective and rapid initiation of RI/FS or
response under other authority
X
X
Specify whether site meets criteria for a removal action
X
Following the remedial PA, an EPA site assessment manager (SAM) determines whether
the site evaluation is accomplished (SEA) or whether there is a need for an SI (which
may be conducted in stages). A SEA recommendation drops the site from further
federal Superfund consideration unless new information becomes available. For sites
that are screened from further evaluation, EPA provides information to states or other
regulatory authorities which may take action on their own.
SACM's single, continuous assessment begins with an initial screening assessment (as
required by the NCP), which combines the objectives of a removal assessment and a
remedial PA.
Removal Preliminary Assessment
Section 300.410(b) of the NCP requires that a preliminary assessment for possible
removal action be undertaken by the lead agency as promptly as possible. For EPA-lead
sites, the OSC is responsible for conducting the assessment to determine the need for a
removal action. Removal site evaluation, in accordance with the NCP, consists of a
removal PA and, if warranted, a removal SI. Objectives of the removal PA are to
determine the presence of a threat, the immediacy of the threat, and proper referral of
the threat to the remedial program.
NCP section 300.410 specifies that the removal PA collect and evaluate readily available
information, including but not limited to:
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Identification of the source and nature of the release or threat of release
Evaluation by the Agency for Toxic Substances and Disease Registry
(ATSDR) or by other groups (e.g., state public health agencies) of the
threat to public health
Evaluation of the magnitude of the threat
Evaluation of factors necessary to make the determination of whether a
removal is necessary
Determination of whether a nonfederal party is undertaking proper
response
The PA may take only a few hours or up to several weeks, depending on characteristics
of the release. PAs for emergency situations rely primarily on existing information and
perhaps a few samples. When characteristics of the incident require longer analysis and
evaluation, the removal PA may include more extensive sampling and monitoring and
review of other site data, such as historical management practices, information from on-
site generators, photodocumentation, and personal interviews (Superfund Removal
Procedures, OSWER Directive 9360.0-03B, 1988).
The OSC incorporates EPA-established special procedures or technical criteria for
complex cases, including evacuation and relocation; contamination of drinking water,
structures and private residences, floodplains, wetlands, and Native American lands; and
contamination due to radioactive wastes and naturally occurring substances. If the
situation indicates response actions are necessary, the OSC conducts a?potentially
responsible party (PRP) search to identify and compel legally responsible parties to take
corrective action.
Section 300.410 (e) of the NCP provides that a PA shall, as appropriate, be terminated
when the OSC or lead agency determines: (1) there is no release or threat of release;
(2) the source is neither a vessel nor a facility as defined by section 300.5 of the NCP;
(3) the release involves neither a hazardous substance nor a pollutant or contaminant
that may present an imminent and substantial danger to public health or welfare; (4) the
release consists of a situation specified in section 300.400 (b) (1) through (3) (naturally
occurring substances) subject to limitations on response; (5) the amount, quantity, and
concentration released does not warrant federal response; (6) a party responsible for the
release, or any other person, is providing appropriate response, and on-scene monitoring
by the government is not required; or (7) the assessment is completed.
If remedial actions under section 300.430 are indicated, the OSC refers the incident,
together with all removal assessment information, to remedial response personnel for site
evaluation pursuant to NCP section 300.420. OSC documentation and notification
requirements ensure that removal assessment conclusions are in the administrative
record and that trustees of any affected natural resources are notified so that they may
initiate appropriate actions pursuant to subpart G of Part 300 of the NCP. OSCs are
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encouraged to submit pollution reports (POLREPs) which also document PAs that do
not require a removal action.
Remedial Preliminary Assessment
The remedial program must perform a PA within 12 months of site discovery and entry
into CERCLIS. If discovery is by direct referral from the removal program or other
notifying reports indicating the site is a critical threat, the remedial program schedules a
PA as soon as possible.
The remedial PA is a screening assessment that distinguishes sites that pose little or no
potential threat to human health and the environment from sites that may pose a
significant threat and warrant further investigation. Under SACM, PA results can
provide to the RDT early indications of the type of response actions needed to clean up
the site. The PA also fulfills public information needs and supports emergency response
and removal activities. Section 300.420 of the NCP states that the lead agency shall
perform a remedial PA on all sites in CERCLIS, as defined in section 300.5, to:
Eliminate from further consideration those sites that pose no threat to
public health or the environment
Determine if there is any potential need for removal action
Set priorities for site inspections
Gather existing data to facilitate later evaluation of the release pursuant
to the HRS, if warranted
The PA is a compilation of readily available information about the site and its
surroundings. It identifies populations and other targets that might be affected by the
site. It includes a reconnaissance of the site and its surrounding environment but does
not include sampling. The PA examines key HRS factors that can indicate a preliminary
HRS score greater than the minimum score for NPL eligibility and that can be evaluated
within the investigation's limited scope. Most (approximately 55 percent) of the 120
hours allocated for the remedial PA are expended collecting data; preparing the report
requires approximately 20 percent of the allocated time (see Guidance for Performing
Preliminary Assessments Under CERCLA, OSWER Directive 9345.0-01A, 1991). The
remedial PA reconnaissance (12 percent of the PA effort) duplicates many activities of
the removal assessment site visit Therefore, a combined site reconnaissance under
SACM represents potential time savings.
The PA provides information on:
Historical waste generation and disposal practices
Hazardous substances associated with the site
Potential sources of hazardous substances
Important migration pathways and affected media
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A comprehensive survey of targets
Critical sample locations for the SI
Data important to the HRS evaluation may not be available during the PA—for example,
analytical data indicating hazardous substance releases and targets exposed to actual
contamination. For these factors, the PA investigator exercises professional judgment
applied in a reasonable and consistent manner to form hypotheses regarding the
likelihood of release of hazardous substaaces and their migration to targets. Some
integrated assessments would warrant collecting critical samples—as in the scope of a
focused SI—to obtain information about the severity of the threats posed by the site (see
Guidance for Performing Site Inspections Under CERCLA, OSWER Directive 9345.1-05,
1992).
The removal and remedial programs perform similar PAs that differ mainly in the extent
to which potential releases and targets are researched and reported. The removal PA
does not investigate all the HRS elements addressed by the remedial PA. Still,
significant duplication of effort between programs occurs at this assessment stage.
2.2.2 Site Inspection
The SI is the first investigation to collect and analyze wastes and environmental media
samples to support site evaluation. The SI supports potential removal and enforcement
actions, collects additional data to evaluate sites using the HRS, or supports remedial
investigations or response actions under other authorities.
/
In the removal assessment process, Regional practices generally do not formally
distinguish a removal SI. Removal preliminary assessments include samples the OSC
determines are necessary to establish threat. In contrast, the remedial site assessment SI
is a discrete sampling investigation to determine releases and actual contamination under
the HRS. For sites that are clearly serious threats, SAMs in some Regions may decide
to combine SI sampling and analysis activities with the remedial PA.
Removal Site Inspection
OSCs perform a removal SI (NCP section 300.410 (d)) when additional information is
needed to make a removal action decision. Completion of the PA is not necessary to
begin a removal SI, and an SI is not required for a site to continue through the removal
decision process.
A removal SI includes an off-site perimeter or on-site inspection. The removal program
documents site evaluation results in a removal assessment report. If the removal site
evaluation concludes that a removal action is not warranted, but that remedial action
may be necessary, the OSC refers the site to the remedial program for evaluation
pursuant to NCP section 300.420.
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Remedial Site Inspection
The remedial program performs an SI if a site poses a significant threat indicating the
need for long-term remediation, or questions requiring a sampling investigation remain
after the PA. The SI supplements PA data through sampling and analysis. NCP section
300.420 (c) describes the remedial SI as an on- and off-site investigation to:
Eliminate from further consideration those releases that pose no
significant threat to public health or the environment
Determine the potential need for removal action
Collect or develop additional data, as appropriate, to evaluate the release
pursuant to the HRS
Collect data in addition to those required to score the release pursuant to
the HRS, as appropriate, to better characterize the release for more
effective and rapid initiation of the Remedial Investigation/Feasibility
Study (RI/FS) or response under other authorities
The SI produces a site-specific sampling plan addressing sampling goals, data quality
objectives, and quality assurance/quality control (QA/QC) issues, and a report
describing waste handling at the site, hazardous substances, migration pathways, human
and environmental targets, and recommendations regarding further action. SI
preparation also requires a work plan, a health and safety plan, and an investigation-
derived wastes plan.
Remedial Sis consist of four major activities: (1) review the available"information,
including analytical data; (2) organize the project team and develop SI plans; (3) perform
field work to visually inspect the site and collect samples; and (4) evaluate all data and
prepare the SI report For some sites, the SI may involve additional tasks to help meet
Sr objectives and support HRS data requirements and emergency response and remedial
efforts. Specifically, the remedial SI investigates:
Release and migration (or threatened release) of a hazardous substance to
drinking water wells or intakes
Release and migration of a hazardous substance to surface water sensitive
environments or fisheries
Presence of a hazardous substance on residential, school, or day care properties
or terrestrial sensitive environments
Release of a hazardous substance into the air
Often the scope of an SI can be limited to sampling to test PA hypotheses to confirm
whether the site has a reasonable chance for placement on the NPL (see Guidance for
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Performing Site Inspections Under CERCLA, 1992). A few strategically located samples
may indicate that no further action needs to be planned, and collecting all information
needed for NPL documentation is unnecessary; in this situation the SI investigator
performs a focused SI. Under SACM, it is likely that combining focused SI activities in
the initial screening assessment will increase efficiency of the assessment process.
At other sites, the scope of the SI can be expanded to fully characterize the threats
because source, release, and target contamination are known during the PA from
previous data, and screening samples are not necessary. An "expanded" SI is reserved for
sites that appear to qualify for the NPL.
The focused SI typically requires 12 to 20 samples (an average of 15) to investigate PA
hypotheses of target contamination and to identify hazardous substances. The number of
hypotheses and critical questions remaining after the PA and the number of pathways
contributing to the further action recommendation influence the scope of the focused SI.
On average, the focused SI requires 350 to 450 technical hours, most of which are spent
preparing for the sampling visit and collecting samples in the field.
The objective of the expanded SI is to collect all data necessary to prepare an HRS
scoring package to propose the site to the NPL. The HRS evaluation and
documentation process requires samples to attribute hazardous substances to site
operations, establish representative background levels, and obtain any missing HRS data
to document pathways of concern. The expanded SI may require special field activities
beyond the screening scope of the focused SI. Special activities may include monitoring
well installation, air sampling, geophysical studies, borehole installation, and complex
background sampling studies.
The expanded SI typically requires 25 to 35 samples (an average of 30) and 600 to 650
technical hours. The complexity of the site and the need for special procedures
determine the scope of the investigation and whether additional technical hours are
required.
At the end of the SI, EPA Regional and state officials decide whether the site should
undergo further investigation (resulting in possible NPL placement and remediation) or
be removed from further Superfund consideration.
2 J Superfund Response Actions
Superfund seeks to address the threats to human health and the environment caused by
uncontrolled hazardous substance releases. This is accomplished by stabilization and
cleanup in two ways: removal actions and remedial actions. The urgency and extent of
the threat, as well as the scope of the response action, determine whether a removal or
remedial action is needed. Removal actions address emergencies and imminent threats,
are simpler in scope and of shorter duration than remedial actions, and are limited to a
cost of $2 million (with special exemptions). Remedial actions address long-term threats,
are complicated and diverse in scope, and are of long duration.
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2.3.1 Removal Action
NCP section 300.415 specifies that the following criteria be considered in determining
the appropriateness of a removal action at NPL and non-NPL sites:
Actual or potential exposure to nearby human populations, animals, or the
food chain from hazardous substances or pollutants or contaminants
Actual or potential contamination of drinking water supplies or sensitive
ecosystems
Hazardous substances or pollutants or contaminants in drums, barrels,
tanks, or other bulk storage containers that may pose a threat of release
High levels of hazardous substances or pollutants or contaminants in soils
largely at or near the surface, that may migrate
Weather conditions that may cause hazardous substances or pollutants or
contaminants to migrate or be released
Threat of fire or explosion
The availability of other appropriate federal or state response mechanisms
to respond to the release
Other situations or factors ^hat may pose threats to public health or
welfare or the environment
Whenever a planning period of at least six months exists before field activities begin, and
the lead agency determines that a removal action is appropriate, the lead agency shall
(a) conduct an Engineering Evaluation/Cost Analysis (EE/CA) of the site, and (b)
complete a sampling plan and quality assurance project plan, if environmental samples
are necessary to evaluate removal action alternatives. OSCs have emergency authority to
initiate activities under $50,000 prior to administrative approval.
Removal actions maintain statutory limits of $2 million in cost and 12 months in duration
from the start of on-site activities to completion. An exemption to the statutory limits
may be granted under CERCLA section 104(c) when the Agency determines that: there
is an immediate risk to public health or welfare or the environment, and continued
response is required to prevent an emergency where no other timely assistance is
available (the "emergency" waiver); or a continued response is appropriate and consistent
with a proposed remedial action (the "consistency" waiver). Section 300.415 of the NCP
places the following conditions on removal actions, which necessitate an association
between the removal and the remedial programs:
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(c) Removal actions shall, to the extent practicable, contribute to the efficient
performance of any anticipated long-term remedial action with respect to
the release concerned.
(f) If the lead agency determines that the removal action will not fully
address the threat posed by the release and the release may require
remedial action, the lead agency shall ensure an orderly transition from
removal to remedial response activities.
232 Remedial Action
Remedial site assessments identify the site as a possible NPL candidate or designate it
SEA and remove it from further Superfund consideration (it may be referred to another
agency such as the state). For NPL candidate sites, EPA begins preparing an HRS
package, applying results of the remedial SI. NPL-candidate designation identifies the
site for potential long-term remediation. Once a site is included on the NPL, a remedy
selection process (in accordance with NCP section 300.430) begins to implement
remedies that eliminate, reduce, or control risks to human health and the environment.
This is accomplished through performance of an RI/FS and preparation of a Record of
Decision (ROD) for the remedial action. Under SACM, the RDT will decide the most
appropriate response action. The designation of early or long-term action distinguishes
short-term prompt risk reduction activities from long-term restoration of surface and
ground water resources.
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3.0 COMPARISON OF ASSESSMENT ACTIVITIES
This section compares technical aspects of the removal and remedial programs, from
statutory requirements to Regional implementation practices. It discusses cross-program
referral; sampling decisions; comparison of activities based on guidance, Regional
documents, and assessment reports; event tracking; and personnel requirements.
3.1 Cross-Program Site Referral
The removal program is notified of numerous accidents, explosions, fires, spills, and
other conditions capable of releasing hazardous substances to the environment—up to
20,000 notifications per year, of which a small number (perhaps 1 percent) require
emergency removal actions, and an even smaller number (perhaps 0.5 percent) require
work to assess appropriate remedial action. The number of "discovered" remedial sites
referred for removal assessment varies but may average 200 to 300 annually. The exact
amount of overlap between assessment sites in the removal and remedial universes is
difficult to quantify, because current practice does not require recording sites referred for
assessment between Superfund's programs. SACM's integrated assessment will be an
efficient process for those sites that remain under Superfund's removal and remedial
clean-up authority.
A study completed in March 1992 (Booz, Allen and Hamilton, Inc.) addressed
programmatic and administrative integration issues, with a focus on communication and
the referral of sites across programs. The study provided preliminary findings from the
Regions and recommended further study of cross-program referrals and communication.
The study found that communication' and coordination between removal and remedial
programs are critical in eliminating duplication of effort. Interviews w^fh Regional
removal and remedial assessment personnel indicated that communication problems exist
within Regions, and that more direct sharing of information and coordination of activities
are necessary.
The study discovered that successful coordination of the two programs is affected by
several key issues, including:
Removal and remedial assessment personnel are usually organized in different
branches or sections, and are located on different floors, in separate buildings,
or different localities.
Different program perceptions may affect the regular transfer of information
between programs. For example, if the removal program determines a site
does not require remedial work, the remedial program might not be notified of
the decision.
The study found that problems resulting from the lack of cross-program coordination
include:
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Duplication of effort exists between the programs.
Workload planning is affected when the removal program investigates a
CERCLIS site without notifying the remedial program, or when the remedial
program refers a site for a removal assessment.
When the removal program decides not to perform a removal action after a
removal assessment, the site information is not always provided to the remedial
program.
Nearby residents may be contacted by different EPA groups unaware that
another program is working on the same site, resulting in a public perception of
Superfund inefficiency.
Many SACM concepts place an increased emphasis on cross-program communication
and coordination. SACM strives to address problems inherent in referring sites between
Superfund assessment authorities. A benefit of improving the sharing of information
between programs is achieving earlier risk reduction at worst sites first.
The above study found that in Regions that currently routinely refer sites between
removal and remedial assessments, communication mechanisms in place include
spreadsheet printouts, specific referral forms, memoranda, and verbal notifications. In
two Regions, program interactions are infrequent, but there has been some coordination;
in one, formal meetings are held twice a year. Two Regions have established formal and
informal communication procedures. In one Region, program team leaders meet at least
twice a week.
Incomplete information regarding the incidence of referring sites to the other program
includes (Regions coded for anonymity):
Region C—The remedial site assessment program refers 20 to 30 sites per year
to the removal program; the removal program refers fewer than 10 sites per
year to remedial site assessment.
Region D—30 to 50 of the 102 sites in the removal program's annual assessment
inventory were referred by the remedial site assessment program; the removal
program refers about 10 sites per year to remedial site assessment.
Region E—The remedial site assessment program refers approximately 20
percent of its sites per year to the removal program.
Region G—During the past two years, the remedial site assessment program has
referred 95 sites to the removal program; the removal program has referred 17
sites to remedial site assessment.
In a Region where the removal and remedial programs were part of the same section,
the Section Chief stated that the two programs work well together because individuals
16
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communicate and there is a mutual commitment.1 One Region publishes a weekly
Superfund Bulletin that lists activities in each program.
32 Sampling Decisions
Data objectives affect sampling decisions within each program. Since program goals
differ, different sampling and analysis protocols are often required. The function of
removal assessment sampling is to better define the extent of known and suspected
threats and to identify treatment and disposal options. Remedial site assessments
investigate all possible threats to four pathways and then narrow them down to the most
significant. However, even with differing program objectives, sampling activities for
removal assessments and remedial site investigations have much in common.
Table 2 presents sampling decisions for both removal and remedial assessments. The
sampling procedures are similar for each program, as described in program Standard
Operating Procedures (SOPs) and Standard Operating Guidelines (SOGs). For example,
procedures for purging and sampling a monitoring well do not vary from program to
program, but sample analysis and ultimate use of the sampling data do vary.
Another difference between sampling objectives of the two programs is that the removal
program often uses one or more types of representative (e.g., grid) sampling to define
sources and threats at a site, with limited QA/QC samples. Representative sampling
may include judgmental (biased), random, and grid locations plus composite samples to
assist in determining extent of contamination. Removal program samples are analyzed
for suspected contaminants based on site history and initial field screening results. In
contrast, the remedial SI uses judgmental sampling and seeks to fully characterize all
possible contaminants present and migrating from sources at the site. This
characterization relies on full Contract Laboratory Program (CLP) Target Analyte List
(TAL) and Target Compound List (TCL) analyses.
One Region successfully addressed different program sampling needs during a combined
assessment pilot by sending approximately 40 percent of the samples collected to a non-
CLP laboratory selected to provide quick results for removal assessment decisions; the
laboratory assigned by the Central Regional Laboratory (CRL) analyzed the remaining
samples to satisfy the more stringent data quality objectives (DQOs) of the remedial site
assessment process.
33 Removal and Remedial Assessment Activities
Table 3 lists assessment activities common to both the removal and the remedial
programs, and Tables 4 and 5 present activities unique to each program. Table 3
illustrates that both programs have many activities in common. Most important, both
programs identify imminent threats to human health, welfare, and the environment, as
well as releases and potential releases of hazardous substances.
'Because of a recent reorganization, separate sections have been established within the branch.
17
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Table 2
Sampling Decisions
Activity
Removal Assessments
Remedial Assessments
Composite sampling
Used often within a source to evaluate
composition and extent of on-site contamination.
Generally .not recommended; can be done within
a single source.
Field analytical screening
techniques and
real-time monitoring
Used regularly with limited fixed laboratory
confirmation samples; used to support removal
action decision.
Used to plan sample locations for EPA's Contract
Laboratory Program (CLP) analysis.
Target Analyte Ust and Target
Compound Ust analysis
Not required; rarely used for removal action
decision, although may be performed for non-tlme-
crttlcal sites; removal analyses limited to known or
suspected contaminants or categories of
substances, determined through field hazard-
categorization test kit analyses.
Recommended at all sites (with some exceptions)
to ensure no screened false negatives.
Source sampling
Emphasis of removal assessment; majority of
samples taken, used to determine threat and
extent of contamination.
Important to identify and attribute all possible
hazardous substances with potential to migrate.
Target sampling
Used only for suspected impact, for example,
residential soils.
SI samples required to investigate actual or
potential contamination within miles of site and
migration influence.
Use of analytical services
Limited CLP or CLP-equlvalent analyses due to
turnaround time aritl,costs.
C"i , •
CLP or CLP-level QA recommended for most
samples; CLP Special Analytical Services used for
all special or unusual analyses.
Number of samples
No prescribed range.
On average, 12 to 20 per SI.
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Table 3
Activities Common to Both Removal and Remedial Assessments
Evaluate response authority, CERCLA eligibility
Perform file search and review existing data
Collect regional and local environmental information
Identify property owneFS and potentially responsible parties (PRPs)
Conduct a title or deed search
Interview state and local authorities, site personnel, and nearby residents
Obtain maps (topographic, geologic, others)
Make telephone calls to collect target and resource use information
Prepare site description and operational history
Prepare source and containment description
Collect source samples
Determine general hydrogeologic, hydrologlc and physical settings
Perform geophysical surveys (e.g., magnetometer)
Describe actual and potential contamination to targets, including:
Ground water drinking water supplies
Surface water intakes
Population in vicinity of site
Sensitive environments and ecosystems
Direct contact, including site accessibility
Evaluate threat of fire or explosion
Conduct site reconnaissance
Observe and document site conditions, generate site sketch, photodocument site
Verify overland flow route
Identify source and nature of release or threat of release
Evaluate threat to public health and environment
Evaluate threat to on-site workers
Conduct sampling and laboratory analysis to demonstrate release to targets
Reporting:
Sampling plan
Site file and logbook
Contractor trip report
PA, SI, or removal assessment reports
Summarize existing analytical data and prior response activities
Recommend health or risk assessment
19
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Table 4
Activities Unique to Removal Assessments
Determine if release quantity or concentration warrants federal response
Assess whether a potentially responsible party Is providing appropriate response
Secure or contain releases in emergency situations
Perform soil gas surveys
Excavate and sample test pits
Perform field analytical screening (e.g., hazard categorization (HAZCAT), air monitoring, grid
sampling)
Conduct representative sampling (e.g., grid), with emphasis on composites
Perform extent of contamination sampling
Assist community relations activities
Track costs
Evaluate response, treatment, and disposal options
Table 5
Activities Unique to Remedial Assessments
Evaluate RCRA eligibility
Describe actual and potential contamination to targets, including:
Fisheries
Sensitive environments
Verify probable point of entry to surface water
Verify targets:
House counts
Surface water targets within 15 downstream miles
Wells within 4 miles
Population within 4 miles
Collect sample from nearest well
Collect samples to demonstrate attribution
Reporting:
PA data and site characteristics form
HRS scoresheets and documentation record, PA-Score or PREscore
20
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The two programs differ in the scope of the assessment activities. For instance, the
removal program generally focuses on on-site surface contamination, while the remedial
program focuses on both on-site and off-site migration. Identification of nearby
population and environmental targets differs. The removal program investigates human
populations and environmental targets affected in the immediate vicinity of the site
within no prescribed distance limit; site-specific conditions determine distance. In
contrast, the remedial program investigates human and environmental targets actually
and potentially affected within specified distance limits from site sources.
Each program's sampling and analytical methods reflect differences in its scope. The
removal program performs limited sampling to demonstrate on-site surface
contamination; remedial investigators conduct limited on-site source sampling, but also
sample to demonstrate contamination at targets. Because of its emergency focus, the
removal program collects samples to provide a representative but quick analysis, which
may include field screening analyses, composite sampling, and the use of non-CLP
laboratories for quick turnaround of results. The removal program establishes no set
guidelines on numbers or types of samples, which vary with the specifics of each site.
The remedial site assessment program provides guidelines on sampling, including
prescribed ranges of numbers and types of samples for the HRS evaluation, which
requires stringent quality assurance levels. The remedial site assessment program
generally does not use composite samples and field screening analyses except to locate
samples for CLP analysis. Removal program sample analysis is often limited to
categories of substances or specific analytes (based on field results), while remedial
program sample analysis includes all the CLP TAL and TCL substances to identify all
potential hazardous materials and to^ avoid false negatives. Section 3.6 provides more
discussion of QA/QC requirements for removal and remedial assessments.
3.4 Event Tracking and Response Reporting
This study briefly examined event tracking and reporting issues, including the removal
and remedial program use of various information management systems. Issues remain
regarding the use of CERCLIS and other databases prior to SACM, and new issues
emerge associated with SACM implementation. Information management issues include:
Differences in program use of CERCLIS
Multiple databases for tracking site activities
Proposed RDT reporting mechanisms
Separate or combined program reporting
Variability of cross-program referral and communication
Timing of data entry (discovery, assessment dates)
Non-standardized site names and identification numbers
Inability to cross-reference information from one database to another or to
build a comprehensive information system
21
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3.4.1
CERCLIS
This study polled Regional and headquarters representatives of the removal and
remedial programs, who indicated that CERCLIS use varies significantly between the
two programs. Remedial personnel in two Regions stated that they enter events, start
and completion dates, and event qualifiers into CERCLIS. Superftmd program
management requires entering an event qualifier (e.g., stabilization, cleanup) with the
completion date for a site activity; all other data are optional. Regional removal
program staff were less certain which types of removal program information they should
enter into CERCLIS. Headquarters requests that the Regions provide all CERCLIS
data element information pertaining to removal actions, but does not specifically require
registering any of the requested information.
At least two Regions track removal assessments in independent in-house databases.
Removal staff often enter sites into CERCLIS either with or without a discovery date
and without notifying the remedial program, which must meet the statutory deadline of
performing a PA within 12 months of site discovery entry into CERCLIS. Removal
program staff asked how sites that have been assessed as no risk may be incorporated
into CERCLIS without necessitating a remedial PA.
Some removal program staff would like to be able to track all removal sites through
CERCLIS, not just sites with removal actions. In at least one Region, the removal and
remedial programs assign different names to the same site, making it difficult to relate
data for the two programs.
3.42 ERNS
The removal program uses the Emergency Response Notification System (ERNS)
database for tracking initial notification of releases, on-scene monitoring, and
assessments. Regions use ERNS as a tool to track initial notification of potential or
actual hazardous substance release incidents, but Regional practices of tracking
assessment and other follow-up response actions through ERNS are variable. ERNS
does not contain extensive information prior to 1987, the date the system became
available.
To accommodate the reporting requirements of SACM, a new or revised CERCLIS
event may need to be added. This event would be applicable to sites where a combined
assessment will be conducted. This event might include decision points to accommodate
sites where only a removal assessment is necessary, only a remedial assessment is
conducted, or where a combined assessment by both programs is conducted. When a
combined assessment is conducted, the remedial program will be responsible for
preparing the assessment report and entering the necessary data into CERCLIS.
3.4.3 SCAP and STARS Targets and Measures
Removal and remedial SCAP and STARS targets and measures are used to plan and
allocate funds for each Region. The Regions must enter the targets and measures into
22
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CERCLIS to provide headquarters with information concerning funding requirements.
Without any other specific data entry requirements, each Region has the option of
entering into CERCLIS minimal or extensive amounts of site information.
3.5 Contractor Support
Contractor staff requirements under dedicated statements of work (SOWs) provide
another basis for comparing programs to examine the technical integration of removal
and remedial assessments. The removal program utilizes the services of the Technical
Assistance Team (TAT) and Emergency Response Cleanup Services (ERCS) contractors,
among others. The TAT contract provides EPA headquarters and the Regions with a
broad range of technical support services for both the oil and hazardous substance
release portions of the emergency response program. Services include sampling,
procurement of field and laboratory analyses, community relations, contingency planning,
training, data management, and quality assurance. TAT also provides support services
for the prevention program, response preparedness, emergency response, and special
projects. The ERCS contract provides actual cleanup services in response to releases of
hazardous substances. Remedial program site assessment work is supported by
Alternative Remedial Contracting Strategy (ARCS) contractors and state site assessment
staffs. The ARCS contracts provide a broad range of program management and
technical services needed to support remedial activities. ARCS contracts are managed
by Regional EPA personnel for tasks such as PAs, Sis, and other site evaluations, well
drilling and monitoring, geophysical investigative support, waste disposal and drum
removal, aerial photography, geotechnical consulting services, and analytical services.
ARCS contracts support site assessment and remedial branches of the remedial program.
Prior to ARCS, the Field Investigation Team (FIT) contracts supported site assessment
work.
The removal program's TAT contract staff and the remedial program's ARCS staff are
composed of a core group of professional technical personnel with similar academic
degrees and training. Each Regional TAT and ARCS contract team is required to
maintain a certain number of technicians and junior and senior professional level staff.
The junior and senior professional levels include geologists, biologists, chemists,
environmental scientists, engineers, toxicologists, and other scientific, technical, and
administrative professionals. The contracts require compliance with OSHA hazardous
waste worker health and safety monitoring and training (OSHA section 1910.120), as
well as technical quality assurance and sampling procedural training and specialized EPA
sample documentation and QA/QC training. Individual training specific to each
program is provided to the staff upon hire and is not a prerequisite to qualify for a
position.
The difference in the basic personnel requirements for the removal and remedial
programs stems from the emergency nature of the removal program. Emergency
response situations require that some persons be available who are capable of
responding to classic emergencies which may require Level A (the most protective)
personal protection equipment, and that a large percentage of the contract personnel be
trained to respond to time-critical and non-time-critical removal situations. Staff
23
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members are specially trained with on-site experience to assess and respond to a release
with limited available data and information. They are on call 24 hours a day for
immediate response to emergency situations. In addition, dedicated TAT contractor
SOWs require the performance of specialized tasks, such as Spill Prevention, Control,
and Countermeasures (SPCC) and Title in inspections and chemical safety audits.
3.6 Analytical Quality Assurance Requirements
Quality assurance procedures in the removal and remedial site assessment programs are
comparable but not exactly analogous, each having a hierarchy of data quality and
verification requirements. Overlap in QA requirements allows sharing of data between
programs.
Comparison of remedial site assessment Data Use Categories (DUCs) (Guidance for
Data Useability in Site Assessment, in development) with the removal program Quality
Assurance (QA) Objectives (QA/QC Guidance for Removal Activities: Sampling, QA/QC
Plan and Data Validation Procedures, April 1990) reveals a degree of correlation between
respective data categories. Removal QA Objectives 1 through 3 are numbered from
least rigorous QA (1) toward most rigorous (3). Remedial site assessment DUCs I
through III are labelled the opposite way: DUC-I is the most rigorous QA. QA
Objective 3 and DUC-I are virtually the same, with the following notable exception: the
defining characteristic of QA Objective 3 is the mandatory analysis of performance
evaluation (PE) samples and eight replicates for statistical error determination. (The
QA3 requirement for error determination has no counterpart in remedial site
assessment.) QA Objective 2 is a verification objective requiring that approximately 10
percent of a sample set undergo external laboratory analysis by EPA methods with
rigorous QA This laboratory subset of QA2 samples meets DUC-I requirements
because it requires identification of analytes, estimated concentration?, and laboratory
QA deliverables similar to those in the Contract Laboratory Program (CLP). QA2 is far
more rigorous than DUC-II and differs from QA3 only in the omission of error
determination and in the number of samples undergoing laboratory analysis. The
combination of analyte-specificity and quantitative results is not included in DUC-II,
DUC-III, or QA1 data, which are regarded as "screening" applications in their respective
programs.
To support NPL documentation, rigorous DUC-I (or CLP-equivalent) data are generally
used. In contrast, the removal program employs its most rigorous objective, QA3, only
about once per quarter, when analytical results approach the action level and error
determination is necessary. At most sites, the removal program relies on QA2 to provide
quantitative or qualitative data to verify field screening results. Confirmation of field
screening by fixed laboratory results is sufficient to demonstrate the need for a removal
action at most sites. Remedial site assessment uses its less rigorous DUCs only to
approximate contamination boundaries and to plan samples for DUC-I analytical
objectives.
The removal QA/QC Guidance specifies data validation requirements consistent with
National Functional Guidelines (1988, 1991). QA3 requires independent validation of
24
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holding times, blanks, calibrations, detection limits, spikes, and validation of elements or
compounds for at least 10 percent of the samples. QA2 requires validation of holding
times, blanks, and detection limits for all samples. In addition, 10 percent of the samples
must undergo full validation of analyte identity or quantitation. QA1 samples are
checked for proper instrument calibration.
DUC-I requires validation of all data elements contained in QA3 plus the additional
validation of PE samples. All analytes in DUC-I data must be validated for a certain
percentage of the data. DUC-II data may be validated for detection limits, blanks,
calibrations, PE materials, and matrix spikes, if desired.
3.6.1 Use of Non-CLP Laboratories
The removal program rarely uses the CLP because routine data turnaround times often
exceed the entire duration of a removal assessment. Because of the urgent nature of the
removal program, OSCs need analytical results as soon as possible, often within 24 hours.
TAT Operating Procedures (OP) for Non-CLP Analytical Services (August 1991) provides a
list of QC options for different analytical methods to allow TAT personnel to specify QC
requirements in exact technical terms. The TAT OP also specifies standard terms and
conditions to enable completing laboratory procurement within 24 hours. (The list itself
is not a QC guidance document.) Non-CLP laboratories must comply with removal
program QA objectives.
The removal program may procure laboratory services from any laboratory not under
EPA debarment. CLP laboratories may be solicited but are not given preference over
other laboratories. Award of laboratory services goes to the lowest bidder responsive to
requested turnaround time and QA requirements. Although the TAT OP provides
choices of standard laboratory QA/QC deliverables, the exact number of laboratory
QA/QC samples (matrix spikes, duplicates, laboratory control samples, etc.) per
analytical package is not standardized. The removal program selects laboratory QA
samples to meet site-specific data requirements; thus the type and number of laboratory
QA samples vary by site.
In contrast, remedial site assessment guidelines recommend that non-CLP analyses
follow CLP requirements for QA and documentation as closely as possible. Non-CLP
data in remedial site assessment must meet certain QA requirements to support NPL
documentation; these are generally more rigorous than removal program QA/QC
requirements. The CLP methods specify standard types and numbers of laboratory QA
samples per batch.
3.62 Analytical Costs
As discussed above, the CLP is used for analyzing samples collected during remedial site
assessments. The average cost for CLP TAL and TCL analyses is $1,100 per sample.
The average laboratory turnaround time is approximately 4 to 5 weeks.
25
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The number of samples collected during a removal assessment varies according to the
site and the nature of the release." Site conditions also determine analytical parameters,
and analyses are usually limited to a few specific substances or types of substances. The
average removal assessment sample has three analytical parameters, a 15-day turnaround
time, and costs approximately $360.
3.63 Data Integration
Tables 6 and 7 compare specific analytical QA and documentation requirements for both
programs. The overlap in the data validation procedures between the two programs
suggests that much of the removal data can be used for remedial assessment. Although
the programs use different laboratories, both programs validate their data according to
National Functional Guidelines. Since QA3 data exceed DUC-I requirements, they are
usable for NPL documentation. However, QA3 data are collected only approximately
once per quarter. Most of the analytical data generated by the removal program meet
QA2 standards. Minimally, 10 percent of QA2 data from analytical laboratories meet
DUC-I requirements and are usable for NPL documentation. QA2 laboratory data
confirm results of field analytical data, so it is possible that an entire set of QA2 data
(approximately 90 percent field analytical data, 10 percent laboratory data) is usable for
NPL documentation. There is precedent in the remedial site assessment program to use
field analytical data associated with laboratory data. Some approximated or qualified
concentration data have been used for NPL documentation if they were associated with
samples analyzed under DUC-I.
Since the removal program does not obtain full TAL and TCL analytical results at every
site, these data may not be usable for NPL documentation even if they come from
appropriate locations and have undergone DUC-I analysis. If a removal data set did
meet all remedial site assessment criteria for sampling location, analytical parameters,
and laboratory QA/QC, the non-CLP package might still be difficult to validate and use.
HRS evaluation with non-CLP data usually takes more time than with CLP data because
validators must review raw data that do not follow a standard analytical format. When
using non-CLP data, validators often depend upon the responsiveness of a laboratory (or
upon payment of additional fees) to obtain quality control results or certifications not
originally requested. Time spent validating a non-standard data package may possibly
negate the savings of using those data in the first place.
Removal assessments and actions will continue to depend upon fast analytical results to
mitigate immediate threats. The HRS evaluation and NPL documentation should apply
QA2 field analytical data to the extent possible. Coordination between the programs
could facilitate transfer of complete sets of removal data to the remedial program. It
may not be cost effective for the removal program to obtain full CLP analyses or for the
remedial program to use available removal data. Future SACM implementation
guidance will provide detailed specifications and guidelines for data quality and
applicability.
26
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Table 6
Analytical OA Requirements
(Page 1 of 3)
Removal
Remedial (Site Assessment)
Level
QA Objective 3
DUC-I
Characteristics
Data Indicate accuracy of concentration levels and
analyte identity. Rigorous quality control procedures
demand high degree of qualitative and quantitative
accuracy. Minimum of eight replicates analyzed to
make statistical error determination. One hundred (100)
percent of samples collected have analyte identification
confirmed by second method (e.g., EPA GC/MS or GC).
Data Indicate accuracy of concentration levels and
analyte identity. Analytical error determinations made for
all samples. Documentation of precision and accuracy.
High level of documentation, and low ppm or high ppb
detection limits minimize uncertainty.
Applications
Applications where action levels are extremely sensitive:
treatment, disposal, site remediation, health risk,
environmental Impact, cleanup verification, pollutant
source identification, delineation of contaminants. QA
Objective 3 rarely used In removal program; requires PE
samples.
Demonstration of a release and Identification of site-
specific indicator chemicals, often at low concentrations.
DUC-i usually required for NPL documentation.
Data Validation
Independent validation of holding times, blanks
contamination, Initial and continuing calibration,
detection limits, spikes, and replicates for all samples.
All elements or compounds validated for at least 10
percent of the samples. Entire contents of every tenth
package from an Individual labqratory is validated.
Automated data validation available.
Independent validation of holding times, blanks
contamination, detection limits, quantitation, initial and
continuing calibration, performance evaluation and
matrix spikes for all samples. Full data review of all
analytes for specified percentage of data. (Percentage
varies by Region.)
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Table 6
Analytical OA Requirements
(Page 2 of 3)
Removal
Remedial (Site Assessment)
Level
QA Objective 2
DUC-II
Characteristics
A subset of field samples (usually 2 10 percent) have
confirmed analyte identification. This subset verifies
results for samples analyzed under less rigorous
requirements. Samples with confirmed analyte
identification meet all analytical requirements for QA
Objective 3 except error determination.
Provides verified, quantitative data. Analyte-specificlty
not required. Only a percentage of analyte identities
verified by rigorous DUC-I analysis and QA.
Applications
Determination of physical and chemical properties of
samples from a release; extent and degree of
contamination; verification of pollutant plume; verification
of pollutant identification; and verification of cleanup.
Removal program most frequently specifies QA
Objective 2 for non-CLP lab analysis. QA Objective 2
lab analysis usually used as verification measure for field
screening.
Determination of extent of contamination boundaries
and other quantitative determinations In situations where
chemical identities are already well established. Rarely
used in remedial site assessment. Has been used in the
past to determine extent of contamination. Samples
intended for DUC-II analysis are almost always
associated with DUC-I samples for confirmation.
Data Validation
Validation of holding times, blanks, detection limits for all
samples. Validation of 10 percent of samples for analyte
identity, quantitation, and replicates. Automated data
validation available.
Optional data validation for detection limit, blanks, Initial
and continuing calibrations, performance evaluation
materials, and matrix spikes.
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Table 6
Analytical OA Requirements
(Page 3 of 3)
Removal
Remedial (Site Assessment Branch)
Level
QA Objective 1
DUC-III
Characteristics
Data provide rapid, preliminary assessment of types and
levels of pollutants. Data generated at this level do not
always provide definitive identification of pollutants or
their concentration levels.
Data provide qualitative analytical information, and
determine gross areas of contamination.
Applications
Determination of physical and chemical properties of
pollutants during release, extent and degree of
contamination relative to concentration differences,
delineation of pollutant plumes, monitoring well
placement, waste compatibility, hazard categorization,
Initial health and safety assessment, preliminary
Identification, or quantitation of pollutants. QA Objective
1 samples are collected at nearly every site that Is
sampled.
Locating contaminated areas, and making preliminary
health and safety decisions. Primarily used to select
sampling areas for DUC-I samples.
Data Validation
Validation checks Instrument calibration, calculations.
Not required.
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Table 7
Data Requirements for Removal and Remedial (Site Assessment) Programs
Data Reporting Requirements
Removal
QA Objective
Site Assessment
DUC
1
2
3
III
II
I
Sample documentation
R
R
R
R
R
R
Chain of custody
R
R
R
R
Documentation of sample collection and analysis dates
R
R
R
R
Sample weight and volume
R
R
R
R
DButlon factors
R
R
R
R
Initial and continuing Instrument calibration data
R
R
R
R
R
Detection limits
R
R
R
R
R
Documented confirmation of analyte Identity
R
R
R
Documentation of sample quantitation
R
R
R
R
Method blanks, trip blanks, rlnsate blanks
R
R
R
R
Error determination with eight replicates
R
Matrix spikes or duplicates
R
R
*
R
Performance evaluation samples
0
R
*
R
Percent of data validated by National Functional Guidelines
R
R
R
Raw data
R
R
Separate reporting of initial analysis and reanalysis
R
R = Required O = Optional
* = At least one Is required.
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4.0 REGIONAL ISSUES
This section examines detailed Regional assessment practices and activities. It
summarizes how removal program data can support remedial site assessment objectives
and how data collected for NPL documentation can support removal assessment
objectives. It draws its results from a comparison of Regional removal and remedial
assessment and removal action reports and a technical survey of all Regions to
characterize removal assessment activities and procedures. This section also identifies
specific removal data that address remedial site assessment data requirements for the
HRS, and the removal program's resource, training, and guidance needs to collect this
information.
4.1 Comparison of Regional Reports
This study compares a sample of Regional removal and remedial assessment and
removal action reports from eight of the ten Regions. The reports present
comprehensive documentation of 13 sites inspected by both programs. The removal and
remedial reports were completed by EPA staff or their TAT, FIT, or ARCS contractors,
and state personnel. Most reports include information on:
Site location and description
Probable cause of release and summary of contamination
Site history, including previous clean-up actions
Summary of waste types, physical state, quantity, and characteristics
Samples and analytical results
Removal assessment and action reports focus on describing the immediate incident,
removal activities, cause of release, efforts to find responsible parties, and a general
assessment of threat to the public and environment. For example, three Region 5 OSC
reports assessing the need for removal actions at a single site between 1989 and 1991
provide a general assessment of public health and environmental threats, including actual
or potential exposure to hazardous substances by nearby populations, animals, or the
food chain; contamination of drinking water supplies or sensitive environments; and the
potential for migration of contaminants in soil. The removal reports examined in this
study did not provide an analysis of potential risk and exposure pathways. An exception
was a Colorado Department of Health removal PA report that comprehensively
described migration pathways, potential targets, and general risk assessment criteria. It
examined a 4-mile radius for number of wells and ground water population, and
potential ground water and surface water contamination. It also investigated the distance
from the site to nearest residences, and population within one mile.
Remedial assessment reports contain specific target information, such as populations
within the site vicinity, surface water use, nearby populations potentially affected by
ground water and surface water contamination, and wetlands and other sensitive
environments which may not be reported in removal assessment reports. In addition to
source and waste characteristics, and ground water, surface water, soil exposure, and air
pathway characteristics, remedial assessment reports identify sensitive environments and
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frequently describe physiography, cultural features, climatology, drainage, soil types,
geology, and stratigraphy. A Region 7 FIT Screening Site Inspection report and a
Wisconsin Department of Natural Resources Site Inspection report examined in this
study both contained these types of information.
Of the small sample of Regional reports this study examined, all removal and remedial
assessment reports met the NCP criteria. Regional removal assessment reports varied
widely in content and format, largely due to incident-specific conditions and the lack of
standard reporting procedures. Remedial assessment reports generally followed national
PA and SI guidance for format and content and addressed a set of migration pathway
and risk criteria more comprehensively than removal assessment reports, which focused
on immediate threat reduction.
4.2 Review of Regional Surveys
Headquarters Hazardous Site Evaluation Division and Emergency Response Division
jointly distributed a questionnaire to Regional EPA removal program personnel (OSCs
and, in Region 1, Site Investigators) and TAT contractors. The questionnaire surveyed
specific assessment activities, including field tasks, analytical data, and laboratory
specifications. Fifty percent of the OSCs responded (representing sue Regions), and 100
percent of the TAT contractors responded. Sections 4.22 through 4.2.9 discuss the
survey results.
Survey respondents noted that the objective of assessing a site is to identify threats.
Respondents use visual observations accompanied by judgmental (biased) sampling
techniques to assess conditions for possible removal action. Specifically, the goal of an
assessment is to determine hazard conditions at a site and to assess whether those
conditions meet NCP criteria for a removal action. Generally, the most critical task is to
identify immediate threats to the population and the environment by investigating
whether hazardous substances are present on site and assessing the potential for their
release. One OSC neatly defined the assessment process: "screen, then focus in."
The removal assessment determines whether a release meets NCP criteria by:
Performing a visual assessment
Researching site history
Conducting interviews
Sampling as necessary to identify the presence and the sources of hazardous
substances at the site with a potential for release
The removal assessment can be as simple as a site reconnaissance and the collection of
one or two drum samples, or it can entail grid samples over a large area. Sample
collection methods, number and location of samples, and types of analyses are dependent
on site conditions.
In all Regions, TAT generally performs the assessment, with the OSC (or Site
Investigator in Region 1) overseeing and determining removal action options, based on
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the assessment results. Regions 1 and 7 have formalized procedures for performing and
documenting removal assessments. Other Regions vary in the degree of detail.
42.1 Removal Action Criteria in Remedial Site Assessments
Table 8 presents the NCP criteria for a removal action (NCP section 300.415(b)(2)(i to
viii)) and indicates whether each item is evaluated during remedial site assessments (PAs
and Sis).
Remedial site assessments typically evaluate many removal action criteria. For example,
remedial Sis investigate hazardous substances in soils, contaminated drinking water, and
contaminated fisheries, and the threat hazardous substances pose to sensitive
environments. In some instances, SI sampling results provide data to initiate a removal
action by the removal program. Two criteria not typically included in remedial site
assessments are weather conditions capable of aiding or causing a release, and
appropriate response by other authorities. These criteria may be considered if flood or
severe storm potential exists or if there is a history of response at the site.
422 HRS Criteria in Removal Assessments
Removal assessment data collection depends mostly on site-specific conditions with no
established list of data needs. The removal assessment must quickly determine the need
for a removal action. The removal assessment does not research and document
populations within a 4-mile radius or 15 miles downstream from the site, as required in
remedial site assessment The removal assessment assesses the population in the
immediate site vicinity, perceived to/be most at risk.
Table 9 presents the site assessment criteria required for the NPL listing process and
indicates whether these criteria are evaluated during a removal assessment. Regional
removal program survey respondents stated that they evaluate other HRS/NPL criteria
such as ground water and surface water uses, intakes, population, and sensitive
environments if site-specific conditions warrant, but it is not done routinely. The
Regions stated that they need guidance and training on HRS requirements and
definitions, plus additional time and resources, to address all remedial site assessment
criteria-
Remedial considerations and HRS data needs routinely addressed during removal
assessments include: determining CERCLA eligibility, conducting a site reconnaissance,
evaluating hazardous waste quantity, assessing overland runoff route, and determining
the potential for contamination of off-site properties. A removal assessment generally
does not assess RCRA eligibility. The removal assessment evaluates hazardous waste
quantity to select a treatment or disposal option and estimate its cost Waste quantity is
an important factor in the remedial ranking evaluation.
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Table 8
Removal Action Criteria in Remedial Site Assessments
NCP Section
300.415(b)(2)
Removal Action Criteria
Evaluated by
Remedial Site
Assessment
(i)
Actual or potential exposure to nearby human populations, animals, or the food chain from
hazardous substances or pollutants or contaminants
Yes
(»)
Actual or potential contamination of drinking water supplies or sensitive ecosystems
Yes
(ill)
Hazardous substances or pollutants or contaminants In drums, barrels, tanks, or other bulk
storage containers, that may pose a threat of release
Yes
(h/)
High levels of hazardous substances or pollutants or contaminants in soils largely at or near the
surface, that may migrate
Yes
(V)
Weather conditions that may cause hazardous substances or pollutants or contaminants to
migrate or be released
No
(vl)
Threat of fire or explosion
Yes
MO
The availability of other appropriate federal or state response mechanisms to respond to the
release
No
(vlll)
Other situations or factors that may pose threats to public health or welfare or the environment
Yes
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9
Remedial HRS/NPL (j
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I he Regions report that they do not generally collect the following HRS data needs
during a removal assessment, unless site-specific conditions warrant: population and
ground water use within 4 miles; geology, occurrence of karst terrain, and depth to
aquifer; and drinking water intakes, fisheries, and sensitive environments within 15
downstream miles. The extent of local geologic and aquifer information collected during
a removal assessment depends on the site; in general, a removal assessment does not
evaluate ground water beyond assessing local drinking water contamination. Although
they report that removal assessments generally do not determine HRS source types, the
Regions do characterize waste sources by type and appropriate amount. They can use
this information directly for the HRS.
Sampling objectives for removal assessments and remedial Sis are generally similar. A
removal assessment may include collection of background, source, release (e.g., ground
water, surface water, sediment, and air), residential property soil, and QA/QC samples.
However, unlike during remedial Sis, removal assessments do not evaluate or even
consider all pathways. The number and types of samples collected depend on the wastes
on site and the threat of probable release off site. Removal program investigators
collect ground water samples only when they suspect that drinking water wells are
contaminated, and residential soil samples only if there is reason to believe that a
property could be contaminated.
Removal assessments often utilize composite samples. This makes it difficult to use the
analytical data for NPL documentation since grab samples are generally needed for
comparability to background and other measures of exposure. Composites are practical
and cost-effective for a removal assessment; grab samples are not practical for
characterizing an entire waste pile to select a treatment or disposal option. The removal
program collects background samples, often composites, to evaluate contaminated soil,
but does not generally require them when assessing other media. As "In remedial Sis,
removal assessments often include judgmental sampling, but they use composites
whenever possible to keep costs down.
Background research as part of a removal assessment, however thorough, does not target
specific HRS data needs since removal assessments do not require this information.
423 Removal Assessment Activities
Removal assessments include a number of specialized activities with little or no
distinction between those performed for PAs or Sis. This trend indicates that there may
be no distinction between these evaluation stages in Regional practice, with the following
exceptions.
Two Regions noted a distinction in activities between assessment stages during the
removal site evaluation. Region 1 performs distinct PAs and Sis. The PA consists of
pre-site visit activities such as collecting background file information, identifying site
owners, and obtaining access to the site. The SI involves visiting the site and sampling as
necessary. Region 4 also distinguishes between those activities completed for a PA and
an SI.
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Region 7 has developed a series of Regional Superfund Removal Procedures manuals for
various removal assessments dependent upon the anticipated type of removal action,
including emergency removal actions, small drum removal actions, and time-critical
removal actions. The manuals include prescribed formats for documentation.
The Regions generally perform the activities listed in Tables 3 and 4 where needed to
determine the presence of contamination and whether a site poses an immediate threat
to public health and the environment. Since every site requires site-specific activities to
fully assess the threats, the activities listed in Tables 3 and 4 will vary by site.
4.2.4 Health Assessment and Risk Assessment
The evaluation of health-based threats (health assessment) determines the need and
urgency of removal actions, the available and feasible risk reduction options, and the
specific action levels or goals. A removal assessment does not include a risk assessment
as strictly defined. OSCs often determine health-based threat in consultation with the
Agency for Toxic Substances and Disease Registry (ATSDR), or based upon federal and
state regulations, EPA directives, or removal program action levels (where these exist).
Region 8 utilizes a staff toxicologist to assist in risk evaluation using data collected by
TAT, although TAT does not perform health or risk assessments. The data used for
removal assessments may be used for risk assessments performed by the remedial
program if the site undergoes long-term remediation.
4.2.5 Reports
The Regions vary in their degree of/reporting and documenting removal assessments.
Documentation varies from a trip or letter report to a report similar in-scope and
content to that required for remedial PAs and Sis. The Regions traclc all sites in some
way, although the methods vary. Most Regions indicated that, at a minimum, they enter
all sites into ERNS. The incident is included in ERNS through an incident notification
form; site information in ERNS is available to all EPA personnel.
TAT documentation of a removal assessment includes, at a minimum, a Technical
Direction Document (TDD) and an Acknowledgement of Completion (AOC). Other
reports that may be required by the TDD include logbooks, photographs, trip reports,
formal reports, and POLREPs.
4.2.6 Site Referral
The survey asked specifically about referral processes for sites receiving a removal
assessment but deemed not to meet the criteria for a removal action. Most Regions
responded that they refer the site to either a state or local agency, or to another EPA
program (e.g., remedial or underground storage tank). They did not report referral
methods in the survey responses. (A respondent from Region 8 noted that since they
enter data for all removal sites into ERNS, this database is available for remedial
program personnel to review as a means of cross-program referral.) Several Regions
indicated that they maintain Regional tracking databases. A Region 1 Site Investigator
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noted that if they perform a full removal assessment (incorporating both PA and SI
activities), they provide copies of the report to remedial site assessment personnel and
state agencies; this process does not apply to emergency action sites, which do not
receive full assessments by the removal program.
Region 9 indicated that they refer most of the sites entered into ERNS to state or local
authorities for follow-up; EPA responds to only a small percentage of the incidents
reported. Of the approximately 5,000 incidents reported in ERNS per year in Region 9,
500 (10 percent) require follow-up phone calls to complete ERNS information, and 100
(2 percent) require a site visit by EPA or its contractors. A letter report is prepared for
all assessed sites. Fifteen (03 percent) of the original 5,000 reported incidents in Region
9 undergo a federally funded removal action.
Section 3.1 of this report provides additional discussion of cross-program site referral.
42.7 Sampling Strategy, Sample Collection and Analysis
Sampling strategy during removal assessments is generally the same in all Regions,
although the procedures and the numbers and locations of samples vary. EPA collects
samples during removal assessments to determine the sources of waste, whether a release
has occurred, and whether a threat exists. Samples are limited to on-site sources except
when the objective is to evaluate imminent risk. EPA may also collect samples to
establish the scope and costs of treatment and disposal options. At some sites, EPA
collects samples to establish extent of contamination to investigate migration of a
release. Collecting environmental (i.e., off-site) samples may be needed to assess threat
but it is not the main sampling objective for removal assessments.
Sampling methodologies vary Regionally and between programs. Remedial Sis generally
perform judgmental sampling to identify hot spots of actual contamination, using a
combination of environmental and source samples, with some QA/QC samples to
confirm data. Removal assessments often use one or more types of representative (e.g.,
grid) sampling to define sources and contaminated soil, but with more limited QA/QC
samples. Representative sampling may include judgmental, random, and grid locations
plus composite sampling (particularly over large areas) to assist in determining extent of
contamination.
Two OSCs described the general Regional approach for a removal assessment: the
Regions use random and judgmental sampling to determine if a removal action is
warranted; they routinely use grid and composite sampling to define migration of a
release (depending upon the apparent extent of contamination). For example, the
Regions may collect random samples at a site with no known history and little visual
evidence of release. They may also use random sampling to select background samples.
Sample number varies and is determined by site-specific conditions such as site area and
terrain. For example, site investigators use grids of small dimension (resulting in more
samples per area) at a small site, but not at a large industrial site. At a small site, grid
spacing can be smaller to define the extent of contamination. At a large abandoned
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industrial site, for example, the first objective is to locate the contamination, the next is
to define its extent. A larger grid spacing is more feasible and cost-effective. If the
smaller site has drums, the investigating team will field screen each with a hazard
categorization (HAZCAT) analytical kit, if possible, and send one sample of each
identified hazard category for off-site laboratory analysis. The team will sample the
surrounding soil if it appears that material within the drums has spilled. On the large
site, the team will set up a grid to collect composite soil samples. They might selectively
sample a large number of drums, based upon label or historical information and
HAZCAT results. The number of samples collected during an assessment can range
from fewer than ten to several hundred, depending on the site and the data needed to
assess the removal action criteria.
Sampling procedures follow Regional SOPs, EPA removal program or Environmental
Response Team SOPs, TAT contractor SOPs, and Quality Assurance/Quality Control
(QA/QC) Guidance for Removal Activities, Sampling QA/QC Plan and Data Validation
Procedures, 1990.
Generally, sampling activities during removal assessments involve extensive field
analytical screening, with a limited number of samples undergoing laboratory analysis.
The investigating team generally sends a minimum of 10 percent of field screening
samples for laboratory confirmation. Region 8 reports that the percentage of samples
sent for laboratory analysis may be more than 10 percent, and may vary considerably,
based on the site and site-specific objectives. For example, at a drum site, the
investigating team may submit for laboratory analysis 20 percent of the total field
samples collected and field analyzed, but at a pesticide site, the team may submit 60
percent. Region 8 TAT indicated that they base the range partly on the category of
sample—10 percent of environmental samples receive laboratory confirmation, compared
to 100 percent of source waste samples. When time allows, the Region bases its decision
to recommend a removal action on laboratory results which confirm field screening
indications. Section 4.2.8 and Table 10 indicate laboratory analyses commonly requested
by all Regions for removal assessments.
Field screening and analysis capabilities vary Regionally, although most Regions utilize
standard monitoring instruments such as photoionization detectors, flame ionization
detectors, radiation meters, and combustible gas indicators/oxygen meters. Most
Regions have available field HAZCAT kits for categorizing waste types, colorimetric
tubes for specific air borne contaminants, and immunoassay kits for such compounds as
polychlorinated biphenyls (PCBs) and pentachlorophenol (PCP) in soil and water. Most
Regions utilize portable X-ray fluorescence (XRF) spectrometers for field screening of
metals. Of more limited availability and use in the Regions are the field gas
chromatography/mass spectrometer (GC/MS) for organic compounds, electron capture
for PCBs and pesticides, and field atomic absorption (AA) for metals. Mobile
laboratories are available in some Regions and are useful when GC use is extensive.
The OSC or Site Investigator selects the methods, analyses, and numbers and locations
of samples, depending on site characteristics and cost considerations. In some cases, the
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Table 10
Removal Assessment Analyses and Costs
Analysis
Range of Costs
($/sample)*
Total (listed) metals and organics
1,000 to 2,000
Volatile organics
125 to 450 (250 to 1,000 for air)
Seml-volatlles or base/neutral/acids
350 to 700
Pestickje/PCBs, PCBs only
145 to 400, 100 to 726
Dioxins
500 to 1,450
Metals (various methods)
17 to 700
Priority Pollutant metals
180 to 240
Toxicity Characteristic Leaching Procedure
125 (metals only) to 1,045 (full)
Ignitability/corrosivity/reactivity
150 to 205 (RCRA)
Asbestos
50
Arsenic
25 to 35
Cadmium
30
Cyanide
30 to 50
Lead
30 to 35
Mercury
30
Sulfides
75
Total organic carbon
40 to 60
Total organic halogens
90
Benzene/toluene/ethylbenzene/xylene
100 to 135
Total petroleum hydrocarbons
50 to 100
pH
10 to 15
Flashpoint
35 to 38
Radionuclides (gross alpha, beta, gamma)**
50
Gamma emitter identification**
125
Cost ranges do not necessarily apply to all Regions. Costs vary due to method, sample medium,
geographical location, and time of year.
Cost data supplemented from other reference.
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OSC or Site Investigator must custom-design the field methods for the data collection
required at a site.
4Laboratory Procurement, Costs, and Analytical Quality Assurance
In the remedial program, the CLP analyzes most of the samples collected by EPA and its
contractors. A small number of samples may undergo specialized analysis through an
EPA Environmental Services Division (ESD) laboratory. Because of time constraints
and special analytical needs, the removal program generally uses one of three strategies
for laboratory procurement and analysis. It contracts most laboratories via a bid process
administered through the TAT (or another) contractor. In most cases this involves three
bids. The removal program usually awards a contract based upon lowest cost and ability
to meet turnaround time (typically two to three weeks). Some Regions prefer the use of
a Regional ESD laboratory for most sample analysis. A Region may use a combination
of Regional labs and the bid process.
Laboratory procurement varies. One OSC noted that in his Region, the removal
program uses CLP laboratories as a last resort because of scheduling issues and delays.
Another OSC indicated that he often requests CLP-equivalent data during assessments.
The removal program uses many of the laboratories that are part of the CLP through the
private three-bid process, not through the CLP scheduling and acquisition process. Table
3 lists common removal assessment analyses and the range of cost per sample analysis,
but does not include the entire range of analyses available. Depending on background
site information and the results of field screening analyses, analysis could also consist of
specific chemical compound identification and quantification (e.g., tetrachloroethene
(PCE) or hexavalent chromium [Cr+6]). Table 3 provides costs as examples and only for
comparison, which may vary with current industry rates.
The remedial program generally requests full TAL and TCL analyses for all SI samples.
Special analytical services comply with some non-routine requests. This standardized
broad screen provides comprehensive and consistent sets of data and the ability to
identify substances not otherwise suspected at a site. The removal program selects
specific analyses based on site historical information, visual assessment data, HAZCAT
and other screening results, and potential waste treatment or disposal options. The
removal program does not specify full TAL and TCL analyses unless no other hazardous
substance definition can be made.
The OSC is responsible for specifying the QA objective and its associated reports from
the laboratory. The objective depends on potential data uses, such as enforcement or
removal action decisions. The OSC may use QA Objective 1 for sample and waste
disposal, and QA Objectives 2 or 3 for litigation. For most removal assessments, the
OSC requests removal QA Objective 2. (See Quality Assurance/Quality Control
(QA/QC) Guidance for Removal Activities, Sampling QA/QC Plan and Data Validation
Procedures, 1990, and section 3.6 of this report for a discussion of the removal program
QA objectives.) Region 4 OSCs confer with the ESD to select a QA objective,
regardless of the laboratory procured. The Regional ESD laboratory, if used, may set ...
the QA standards without input from the OSC. The QA objective selected by the OSC
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and its associated requirements determine the QA/QC samples collected in the field.
Field QA/QC samples typically include field and trip blanks, replicates (duplicates),
matrix spike/matrix spike duplicates, and performance evaluation (PE) samples.
42.9 CERCLA Eligibility
Remedial site assessments involve determining CERCLA eligibility, generally prior to
the PA reconnaissance. If the site is subject to the corrective action authorities of
RCRA Subtitle C, Regional EPA site assessment staff will decide whether to address the
site under CERCLA or refer the site to the RCRA program. RCRA Subtitle C sites
include currently operating RCRA treatment, storage, or disposal facilities (TSDFs);
TSDFs that operated after November 19, 1980; RCRA converters that are former TSFs
with current RCRA "generator" or "non-handler" status; and RCRA non-,or late filers.
CERCLA authority excludes releases or threatened releases of crude oil, fractions of
crude oil, or refined crude oil products; sites that hold a Nuclear Regulatory Commission
license; and sites that fall under the jurisdiction of the Atomic Energy Act and the
Uranium Mill Tailings Radiation Control Act
Removal assessments, however, do not require regulatory review for eligibility. In
emergencies, EPA responds to all sites; there is no time prior to the investigation to
determine eligibility for CERCLA funding. For non-emergencies, the removal program
generally assesses CERCLA eligibility, but procedures vary between the Regions. Four
Regions note special circumstances to investigate a site that does not fall under
CERCLA authority (in most cases these are RCRA-regulated facilities). Survey
responders noted that the OSC or other EPA representative, not the contractor,
performs eligibility checks.
If EPA concludes that a site is a RCRA-regulated facility, in some Regions OSCs or Site
Investigators work with RCRA inspectors to complete the investigation; in others, the
RCRA program proceeds alone. The role of the removal program varies depending on
hazards present, PRP involvement, and other factors. The OSCs role may be either to
investigate imminent threat conditions or emergencies or to assist the complete
investigation to assess threat. In emergencies, the OSC performs an assessment, as at
other removal sites.
4.2.10 PRP-Lead Sites
If time allows and the PRP is willing and able to respond, OSCs in all Regions provide
some oversight and, in some Regions, monitor PRP-lead investigations and actions.
Monitoring may consist of field screening for health and safety compliance and concerns,
collecting split samples from the PRP, or collecting confirmatory samples. TAT
generally supports EPA oversight and may review PRP-prepared work plans or health
and safety plans, collect or receive split or confirmatory samples, or document activities
for compliance with the NCP and agreements with EPA. Region 7 noted an exception
to OSC oversight: the remedial program's Technical Enforcement Services (TES)
contractor oversees most PRP activities.
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Documentation at PRP-lead sites may consist of POLREPs, photodocumentation,
logbooks, and contractor reports. OSCs noted that they must prepare action memoranda
for PRP-lead sites, which serve as the basis for enforcement administrative orders as well
as contingency planning if the PRP ceases action at the site.
If a site requires emergency action and a PRP has been found, EPA operates as at any
other emergency site: EPA's enforcement program seeks payment from the PRP for the
work performed at the site. If an emergency arises at an ongoing PRP-lead site, EPA
addresses the emergency and seeks to collect costs from the PRP.
4.3 Summary of Regional Issues
Regional survey responses indicated that screening assessment activities and criteria lend
themselves to program integration, as these activities vary little between the removal and
remedial programs. The surveys identified areas where the programs are different:
The removal program must feasibly and cost-effectively address the objectives
of a removal action, which focuses on limited and specific threats, whereas the
remedial program must evaluate specific factors and threats of the HRS.
Survey respondents indicated that although a typical removal assessment does
not currently require all HRS evaluation criteria, they could collect the data if
provided with HRS guidance and training plus additional time and resources.
Both programs have similar sampling objectives, but the removal program
collects samples to better define extent of known and suspected threats and
identify treatment and disposal options. The remedial program investigates all
possible threats to four pathways and narrows them down to4he most
significant.
The removal program collects samples to evaluate treatment and disposal
options.
The removal program uses composite samples for determination of threat,
whereas composites are not appropriate for some objectives of remedial site
assessments.
Depending on site-specific characteristics, a removal assessment collects fewer
than ten to several hundred samples for analysis; the typical remedial SI
collects 10 to 20 samples.
Because of cost considerations and the need for quick turnaround results, the
removal program generally utilizes private or ESD laboratories procured by bid
process; remedial site assessments analyze most SI samples by the CLP.
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The removal program tracks site activities through the ERNS database, while
the remedial program uses CERCLIS (also used by the removal program, but
in a more limited scope).
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5.0 SUMMARY
EPA conducted this study to examine where the removal and remedial programs perform
similar activities or have similar assessment objectives. Regional survey responses and
the review of Regional reports support the conclusions that assessment activities and
criteria lend themselves to program integration. Except for special training to respond to
emergencies, the current technical contract personnel available to both programs should
meet program objectives with minimal additional training. Specifically, the potential
exists for: (1) integrating removal and remedial PAs and Sis, enabling one field team on
one site visit to meet the data requirements of both programs (for non-emergency
situations) and to support decisions regarding Superfund response actions; and (2)
integrating data usability standards and redefining QA/QC requirements.
5.1 Integrated Site Assessment Implementation Issues
This study identified differences in procedures between the two programs as well as
Regional variations within the removal program. The remedial program has national
guidance for performing PAs and Sis which ensures collection of the data necessary to
complete site evaluations. The removal program has no national guidance, other than
the NCP, detailing the specific criteria to be evaluated during removal assessments.
Because of the need for flexibility to respond to a range of time-critical conditions,
removal sites vary greatly in the methods used to address regulatory criteria. Within the
removal program, the Regions vary significantly in methods and procedures; the remedial
program varies only slightly in assessment procedures within Regions because of the
standardized national guidance requirements. Regional differences affect site
assessment, notification procedures, and reporting requirements, particularly the use of
CERCLIS and ERNS databases.
Tables 2 and 6 summarize sampling decisions and analytical quality assurance objectives
of both programs. Assessment integration requires that the data generated by the
removal program be validated and accepted for use by the remedial program. Each
Region will therefore need to support similar data quality objectives, which will help
maintain consistency of site evaluation by the RDT within a Region, as well as between
Regions.
5.2 Methods For Achieving SACM Goals
The following guidelines may help to achieve more efficient assessment of Superfund
sites:
1. Work concurrently, where possible. Evaluating the need for removal action and
remediation can be a single early stage of assessment, and assessment work can
continue concurrently with early actions and enforcement or PRP searches. When
one program works at a site, the data and samples collected should support the other
program.
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Specific functions need not be completed before other functions can start. However,
documentation required by the NCP must be completed before moving from one
phase of assessment to another, and the necessary documentation for both programs
must be met.
Integrating assessment functions can cut several years from the assessment and clean-
up process by:
Eliminating duplicative activities during scoping and site characterization
(e.g., health and safety, sampling and analysis, administrative activities)
• Combining assessments to realize efficiencies in site evaluation, reporting,
sampling, communication, and early risk reduction
Referring SEA sites to the states or other regulatory authorities for further
action, as appropriate
2. Minimize the lag time between programs working at a site. If one program uses
data generated by another program, then the time taken by the second program to
mobilize for the site will be minimal. For example, the initial health and safety plan
can be modified for subsequent site work, rather than using time to create a new
plan.
3. Implement the "one-door" concept as far as possible. Many calls received by the
NRC are not eligible for response. If emergencies are immediately diverted to the
removal program, and only the non-time-critical actions referred to remedial, EPA
can manage a large percentage of potential releases early in the prpcess. More
inter-program cooperation and prompt and complete notification practices will help
facilitate referrals for site assessment.
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REFERENCES
Booz, Allen and Hamilton, Incorporated. 1992. Notes From the Brainstorming Session
on Removal/Site Assessment Integration, 1992 Annual Site Assessment National
Conference. Prepared for the U.S. Environmental Protection Agency.
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response.
Piloting the New Superfund Accelerated Cleanup Model... Memorandum from
Richard J. Guimond, Assistant Surgeon General, U.S. Public Health Service, dated
March 10, 1992.
U.S. Environmental Protection Agency. 1988. Preliminary Assessment Petition. Office
of Emergency and Remedial Response. Publication 9200.5-301FS.
U.S. Environmental Protection Agency. 1988. Superfund Removal Procedures. Office of
Solid Waste and Emergency Response. Directive 9360.0-03B
U.S. Environmental Protection Agency. 1990. National Oil and Hazardous Substances
Pollution Contingency Plan. 40 CFR Part 300. 55 FR 8666, March 8, 1990.
U.S. Environmental Protection Agency. 1990. Quality Assurance/Quality Control
(QA/QC) Guidance for Removal Activities: Sampling, QA/QC Plan and Data
Validation Procedures. Office of Solid Waste and Emergency Response. Directive
9360.4-01, interim final.
U.S. Environmental Protection Agency. 1991. National Functional Guidelines for
Organic Data Review. Contract Laboratory Program.
U.S. Environmental Protection Agency. 1988. Laboratory Data Validation Functional
Guidelines for Evaluating Inorganic Analysis, Contract Laboratory Program.
U.S. Environmental Protection Agency. 1991. Guidance for Performing Preliminary
Assessments Under CERCLA. Office of Solid Waste and Emergency Response.
Directive 9345.0-01A.
U.S. Environmental Protection Agency, Region XIII, Technical Assistance Team. 1991.
Operating Procedures (OP) for Non-CLP Analytical Services.
U.S. Environmental Protection Agency. 1991. Technical Assistance Team (TAT)
Contract Users' Manual. Office of Emergency and Remedial Response. Directive
9360.6-08.
U.S. Environmental Protection Agency. 1992. Guidance for Performing Site Inspections
Under CERCLA. Office of Solid Waste and Emergency Response. Directive
9345.1-05, interim final.
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U.S. Environmental Protection Agency. 1992. Superfund Accelerated Cleanup Model
(SACM). Don R. Clay Memorandum, April 7, 1992. Office of Solid Waste and
Emergency Response. Directive 9203.1-01.
U.S. Environmental Protection Agency. 1992. Guidance on Implementation of the
Superfund Accelerated Cleanup Model (SACM) Under CERCLA and the NCP.
Don R. Clay and Lisa Friedman Memorandum, July 7, 1992. Office of Solid Waste
and Emergency Response and Office of General Counsel. Directive 9203.1-03.
U.S. Environmental Protection Agency. 1992. Transmittal of SACM Short Sheets
(9203.1 - 051). Henry L Longest II and Bruce Diamond Memorandum, December
31, 1992. Office of Emergency and Remedial Response and Office of Waste
Programs Enforcement. Publication 9203.1-051, Volume 1, Numbers 1-5.
U.S. Environmental Protection Agency. Guidance for Data Usability in Site Assessment
(in development). Office of Solid Waste and Emergency Response. Directive
9345.1-06.
SUPPLEMENTAL REFERENCES
Regional Assessment Reports:
Colorado Department of Health, Hazardous Materials and Waste Management Division.
1990. Preliminary Assessment Colorado Fireworks Specialties aka Loveland
Fireworks, Loveland, CO.
U.S. Environmental Protection Agency, Region VII, Field Investigation Team. 1989.
Preliminary Assessment Leavenworth Junkyard Site, Leavenworth, KS. TDD No. F-
07-8809-10.
U.S. Environmental Protection Agency, Region VIE, Field Investigation Team. 1989.
Final Westchem Warehouse Preliminary Assessment, Minot, ND. TDD No. F08-
8904-13.
U.S. Environmental Protection Agency, Region IV. 1990. Harlan County Drum Site
Investigation Report, Atlanta, GA.
U.S. Environmental Protection Agency, Region VII, Field Investigation Team. 1990.
Final Report Screening Site Inspection at Leavenworth Junkyard Site, Leavenworth,
KS. TDD No. F-07-8903-013.
U.S. Environmental Protection Agency, Region VII. 1990. Removal Assessment for
Leavenworth Junkyard, Leavenworth, KS.
U.S. Environmental Protection Agency, Region I, Technical Assistance Team. 1991.
PA/SI Report, Stamina Mills Site, N. Smithfield, RI.
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U.S. Environmental Protection Agency, Region II. 1991. Federal On-Scene
Coordinator's Report, 37 Aqueduct Street, Ossining, NY.
U.S. Environmental Protection Agency, Region IV. 1991. Harlan County Drum Site
Removal Report, Atlanta, GA.
U.S. Environmental Protection Agency, Region XII, Technical Assistance Team. 1991.
FIT Survey.
U.S. Environmental Protection Agency, Region I, Alternative Remedial Contracting
Strategy. 1992. Task Work Plan for On-Site Reconnaissance and Sampling at Geer
Brothers Septic, Waterford, CT. TDD No. 9105-72-AWS.
U.S. Environmental Protection Agency, Region I, Alternative Remedial Contracting
Strategy. 1992. Trip Report for On-Site Reconnaissance and Soil Sampling at
Jefferson Garden Apartments, New London, CT. TDD No. 9105-73-AWS.
U.S. Environmental Protection Agency, Region I, Technical Assistance Team. 1992.
After Action Report, Stamina Mills Site, N. Smithfield, RI.
Removal program staff in the following Regions responded to a technical survey:
Region 1 Three EPA and three TAT responses.
Region 2 Three TAT responses.
Region 3 Three TAT responses.
Region 4 One EPA and one TAT response.
Region 5 One TAT response.
Region 6 Two EPA and one TAT response.
Region 7 One EPA and one TAT response.
Region 8 One EPA and one TAT response.
Region 9 Two EPA and one TAT response.
Region 10 One TAT response.
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