EPA-540-F-98-040
OSWER 9200.1-25P
PB98-963255
UNITED :TATES ENVIR "NMENTAL PROTECT-ON AGENCY
WASHINGTON, D.C. 20460
SEP 3 1998
OFFICE OP
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Regional Site Assessment Priorities Plans
OSWER Directive 9200.1 -25P
FROM: Stephen D. Luftig, Director
Office of Emergency and Remedial Response
TO: Superfund National Policy Managers, Regions I-X
PURPOSE
The purpose of this memorandum is to request that the regions prepare regional
site assessment priority plans describing the approach each region will take to address
the backlog of sites currently in CERCLIS, sites deferred to RCRA where there may be
of Superfund interest, and sites which will enter CERCLIS in the near future. These
plans were the subject of the recent site assessment meeting in Denver, July 27th and
28th, where regional representative agreed on the plans' scope. I envision these plans
as important tools in communicating the region's individual approaches and priorities for
assessing sites over the next few years. The information you gather for these plans
can support the broader Superfund program-wide, long-range planning being done by
the Future of Superfund Workgroup, which is made up of regional and Headquarters
representatives.
BACKGROUND
At the meeting in Denver, regional site assessment managers and members of
my staff discussed the backlog of sites needing preliminary assessments (PAs), site
inspections (Sis) and expanded site assessments (Sis). They also talked about
addressing sites that were the subject of the GAO survey of sites which rank and are
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awaiting listing decisions, and the EPA Office of Inspector General's audit of sites
Deferred to RCRA. In addition to these sites, we should keep in min^ that we add
approximately 300 new site into CERCL1S each year. Through an initial information
gathering survey and regional discussions, it is obvious that the workload varies in
depth and scope among the 10 regions. For example, some regions have a significant
backlog of sites needing PAs or Sis but have few sites that are awaiting a listing
decision; other regions might have a minimal backlog of site awaiting PAs and Sis, but
may need to examine the need to put more resources into making Superfund decisions
at a large number of sites incorrectly deferred to RCRA.
IMPLEMENTATION
In past years, OERR has issued a site assessment priorities
memorandum to provide guidance to regions on making workload prioritization
decisions. In early FY99 Headquarters plans to issue a memorandum communicating
national site assessment priorities. At this time, we are asking regions to prepare
individual plans that discuss their assessment approaches tailored to their specific
workloads. The information you provide will be used to support the national site
assessment priorities memorandum,
OERR has identified strengthening programs that assess sites and initiate the
pipeline as a priority for FY 99. Further, GAO is evaluating whether the site
assessment program is adequately identifying the sites which pose the greatest risk.
The national site assessment priorities memo should address these concerns and touch
on identifying the highest priority sites in RCRA deferral inventory and sites awaiting
listing decisions with human exposure. OERR's emphasis in all areas will be on
identifying the best approaches for prioritizing and addressing the backlog of sites
needing assessment and listing decisions and providing guidance to regions on
implementation of these approaches. OERR will continue to streamline the listing
process to support listing of appropriate sites. OERR and OSRE are drafting a joint
memorandum to regional management which will discuss our position on listing sites.
The regional representatives attending the Denver meeting agreed on a basic
outline for the priorities plans. The outline establishes topics that at minimum, should
be discussed in the plans. Regions may enhance their plans with additional topics as
appropriate. For example, the national site assessment priorities plan will not touch on
Federal facilities or brownfield activities, but some regions may include this information
if desired.
To the extent possible, please discuss the priority each site type has in your
region and how yoĞ i anticipate addressina each type. This discussion may include use
of removal authorities, State programs, and listing sites on the NPL. It should also
identify what site categories may not be addressed, given the current budget.
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DRAFT Outline for Development of Regional Priorities Plans
1. Conventional site assessment activities
a. Site discovery/pre-screening sites
b. PA inventory - estimate size of inventory, give assumptions made in
calculating estimate, and summarize plan for addressing inventory
c. SI/ESI inventory - estimate size of inventory, give assumptions made in
calculating estimate, and summarize plan for addressing inventory
d. Other site assessment tools (abbreviated PA, combined PA/SI)
e. NPL process
f. Federal facilities (not required but may be included in some Regional
plans)
g. Integrated assessments
h, Resource/FTE implications
2, GAO sites
a. Need to make final decisions on these sites
b. Strategy developed at July 1998, SAM meeting (highest priority is high
risk sites with human exposure)
c. Resource/FTE implications
3. RCRA deferred sites (IG sites)
a. Issue of monitoring deferred sites and progress
b. Discussed at July 1998, SAM meeting and draft strategy developed (first,
site identified as high priority and sites with limited information available)
c. Resource/FTE implications
4. State, Tribal, and Local Relationships
a. Develop strategy for relationships
b. Community involvement at selected sites
c. Resource/FTE implications
5. Brownfields sites (not required but may be included in some Regional plans)
a. Resource/FTE implications
6. Future of Site Assessment Program
a. Site assessment strategies
b. Planning for different categories of sites
Tentative workload strategy schedule: The regions agreed to submit their draft priorities
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plans to their OERR Site Assessment Regional Coordinator before October 1,1998.
The OERR Site Assessment Team (SAT) will review the draft plans, look for
commonalities and consolidate the information. Also during October, and based on the
regional draft plans, the SAT will develop a draft national site assessment priorities
plan. The consolidation of the regional plans and drafting of the national plan will be
ready for the site assessment managers meeting scheduled for the last week in
October, in Seattle. At that meeting regions and Headquarters will reach agreement on
outstanding issues and develop recommendations for the Focus Forum scheduled for
the first week in November, in Dallas and National Policy Managers Meeting scheduled
for December 2-4 in San Francisco. The regional and Headquarters' plans will be
finalized in late December, 1998.
As each region reviews the site specific information, to the extent possible and to
aid in planning, please provide information on availability of potentially responsible
parties and information describing various site types (mining, residential communities,
defunct RCRA facility). I recognize that in some cases you will not have enough
information to provide a detailed strategy. I expect that these regional site assessment
priorities plans will need to be modified as you learn more about the sites. The plans
should represent the regions best sense, given current information, of how you intend
to address the backlog of sites in the program and any new sites anticipated. I
encourage you to discuss your priorities with your States and Tribes before the next
meetings on this topic in Seattle and Dallas,
Please forward your region's draff plan to your regional site assessment
coordinator before October 1, 1998. The OERR Site Assessment Team will compile
the information for a discussion at the site assessment meeting scheduled for late
October or early November. If you have any questions on this memorandum or the
regional site assessment priority plans, contact Bob Myers (703) 603-8851.
cc: Tim Fields
Cliff Rothenstein
Mike Shapiro
Patricia Tidwell
All OERR Center Directors
All OERR Senior Process Managers
OSWER Office Directors
Barry Breen
Carolyn Offut
Joanna Gibson
Mike Hurd, Regional Coordinator Regions 1 and 9
Terri Johnson, Regional Coordinator Regions 2 and 6
Frank Avviisato, Regional Coordinator Regions 3 and 8
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Dan Thornton, Regional Coordinator Regions 4 and 10
Jeff Phillips: "^egiona1 Coordinator Regions 5 and 7
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