UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAV 2 2 1996
OFFICE Cf
SOLID WASTE AND EME RC£
RESPONSE
OSWER Directive 9200.1-17
MEMORANDUM
SUBJECT: Focus Areas for Headquarters Support for Regional
Dec j^ion^-MaklTlg k /)
FROM: r e Jt o r
^_Q£rice{ oflEmergencry and Remedial Response
TO: Director, Office of Site Remediation and Restoration
Region I
Director, Emergency and Remedial Response Division
Region II
Director, Hazardous Waste Management Division'
Regions III, IX
Director, Waste Management Division
Region IV
Director, Superfund Division
Regions V, VI, VII
Assistant Regional Administrator, Office of Ecosystems
Protection and Remediation
Region VIII
Director, Environmental Cleanup Office
Region X
Purpose
This memorandum outlines the technical and policy areas the
Office of Emergency and Remedial Response (OERR) is focusing its
regional coordination efforts on in FY 1996 to promote
appropriately consistent program implementation and effective
communication between Headquarters and the Regions.
Recycled/Recyclable
Printed with Soy/Canola Ink on paper that
contains at least S0% recycled fiber
-------
Background
These focus areas represent critical program areas that
warrant special attention by Regional and Headquarters management
and staff because they 1) have a dramatic impact on the ultimate
cleanup decisions EPA makes; 2) they entail issues of intense
public, Congressional, and stakeholder interest; and/or 3) they
are areas where the policy is changing rapidly due to new
understandings in science or technology. Targeting regional
coordination will promote continuous improvement in the quality
and public understanding of EPA's response decision making in
those areas where the coordination will have the greatest impact.
Appropriately consistent implementation of national program
guidance and policy, and effective communication, will go far
toward demonstrating the rationality, fairness, and
predictability of our decisions, and enhancing the Superfund
program's overall credibility.
The goal of consistent implementation is that we all share a
common understanding of program policies and, as a result, employ
similar rationales in response selection rather than having, for
example, the same cleanup level or identical technologies at
every site. Hence, the purpose for focused support for Regions
is to ensure this common understanding and credible decision
making across Regions and to encourage transparent presentation
so that those outside the Agency understand our decisions.
This effort builds on the long-standing tradition of
regional coordination in OERR. While the level of involvement of
Headquarters staff in supporting response selection has varied
over the years, we are now in a period where a strong partnership
between the Regions and their Headquarters counterparts on key
technical and policy issues related to response selection
decisions is crucial.
The persistence and prominence of national consistency as a
concern among stakeholders inspired a special meeting of the
Waste Management Division Directors in summer of 1995 in Chicago.
Areas of concern discussed at that meeting became the focus of a
consistency initiative during the latter part of FY 1995. Under
this initiative Headquarters staff reviewed proposed plans and
draft records of decision (RODs) that related to the focus areas.
- 2 -
-------
developed information on program performance, and suggested
alternate language or approaches for some RODs.
In October 1995, OBRR's reorganization placed an emphasis on
program implementation and the promotion of full program
integration begun under the Superfund Accelerated Cleanup Model
(SACM) through the establishment of five Regional Accelerated
Response Centers, each of which has responsibility for supporting
two Regions in their site assessment, removal, and remedial
activities.
Continued focus on some key policy areas remains important
this fiscal year. These focus areas will enable us to tell the
story of our program implementation efforts in a more effective
way. Through more direct support of Regional decision making in
critical areas and the inclusion of an evaluation component in
the process, we will be able to identify trends and good examples
of effective implementation we can share nationally, with
Congress, States, ana the public.
Implementation
^ Jr ~ w .r.rn.iT"'..tt ^
This memorandum provides a strategy for OERR and the Regions
to work together as partners to ensure that the directives and
guidance related to the identified focus areas are implemented in
an appropriately consistent manner across all Regions. A key
element of focused regional coordination is ensuring that Regions
receive and understand all policies related to the four focus
areas. To the degree that resources allow, Headquarters will
provide face-to-face presentations on the focus areas to
appropriate Regional personnel. It is important that all of us
share an understanding of the policies related to the focus areas
so that thev can be incorporated into site activities as earlv as
possible. OERR staff will continue to support Regions on any
technical or policy issue that arises, although we will make
special efforts to promote understanding of these key issues and
facilitate effective decision making with respect to them.
Since decision documents provide one of the most succinct
and objective demonstrations of policy implementation, they will
be used to assess our progress in implementing the focus areas,
as was done last year. Review of draft documents provides an
opportunity to positively impact decision documents before they
- 3 -
-------
are made final. Our purpose is to ensure that Agency decisions
are clear and consistent in presentation and content and not to
second-guess Regional decision-making. However, we will flag
inconsistencies and expect to work through such issues as may
arise. Headquarters will also compile results for discussion at
year's end. This will allow us to gauge our progress toward
continuous improvement and to shift our focus to other areas, as
appropriate.
Non-Federal Facility Sites: To implement this effort. Regions
should send their draft proposed plans to the appropriate
Accelerated Response Centers for review. The Accelerated
Response Centers will determine the need to obtain draft RODs;
and we will prioritize our further attention on those documents
based on their relation to the focus areas. For non-time-
critical removal actions, the Region should contact the
appropriate Regional Coordinator to determine the need to send in
the draft Engineering Evaluation/Cost Assessment or Action
Memorandum. We will work diligently to accomodate Regional
schedules in providing our feedback to you. Sending these
documents to Headquarters will enable us to document the national
progress of the Superfund program, as well as demonstrate
effective implementation of the focus areas. In addition, some
compilation of national statistics regarding the focus areas will
be developed from review of draft dacision documents.
Federal Facility Sites: The Federal Facilities Restoration and
Reuse Office (FFRRO) will look at decision documents for Federal
Facility sites, to the extent that FFRRO Headquarters staff can
meet necessary site-specific schedules, particularly where the
Region has an interest in Headquarters review. Therefore, draft
decision documents for Federal Facilities should be sent to
FFRRO. OERR will provide assistance to FFRRO as needed on
technical issues associated with the focus aireas.
FOCUS AREAS
OERR's Regional Accelerated Response Centers will focus
particular attention on the following four areas:
Risk management and cost-effectiveness decision
documentation: ensuring that all Superfund decision
- 4 -
-------
documents clearly present the risks that warrant taking an
action, how the risks will be addressed by the response
action, the other benefits of the response action, the
response costs, and how it was determined that the
effectiveness of the response justifies the cost. Risk
management decisions include land use and exposure
assumptions, which should be reasonable, not speculative;
Ground water policy: ensuring implementation of the phased
approach to ground water remediation, use of the.Technical
Impracticability Guidance, and measurement of response
performance;
Lead policy: ensuring implementation of the OSWER lead
directive {OSWER Directive #9355.4-12) issued in July 1994,
including the use of the integrated exposure and uptake
biokinetic model (IEUBK);
Presumptive remedies: ensuring implementation of
presumptive remedy guidances at all appropriate sites and
measuring resulting impacts (e.g., time and cost saving).
Attachment 1 to this memorandum describes each focus area in
more detail, highlighting why each focus area has been
identified, and explains the Regions' and Headquarters'
anticipated roles.
The four focus areas apply to response actions taken under
both removal authority and remedial authority, although the
specific application of guidance in a particular area may be
different depending on the specific authority involved. For
example, the clarification of risk management and cost-
effectiveness decisions should be tailored to the specific
decision document and the magnitude of the response. For some
actions performed under removal authority, the discussion of
risks to be addressed and the benefits of the response may be
qualitative and less detailed than that for more complex,
extensive actions for which more detailed information will be
available. In contrast, however, presumptive remedies identify
appropriate technologies for specific situations, regardless of
the response authority. Similarly, when developing a final
response action that addresses lead problems, cleanup levels
- 5 -
-------
should consider health-based levels developed with the IEUBK for
both removal and remedial actions. The attached outlines provide
more detail on specific implications for actions under -removal
authority.
REGIONAL COORDINATION
Each of the five Regional Accelerated Response Centers in
OERR has designated several staff to serve as Regional
Coordinators for the two Regions that each Center is designed to
serve. These staff are specifically charged to work with the
Regions to resolve general and site-specific policy issues of
concern; to provide the Regions with guidance, expertise, and
national policy perspectives; to collect and analyze information
from the Regions on program implementation, and to promote
Regional involvement in the development and implementation of new
Superfund initiatives. Attached is a list of Headquarters staff
and their responsibilities for regional service.
These Regional Coordinators will assist the Regions with the
implementation of these focus areas. They can help ensure that
pertinent information regarding the focus areas (e.g., guidance,
directives) is disseminated to the Regional staff and management.
They can also assist Regions in achieving the specific goals for
focus areas by providing project managers with relevant
information or specific contacts with subject matter experts, as
necessary. Additionally, they will help Headquarters tracking
and/or evaluation activities that will be conducted to assess our
progress and tell our story.
OTHER IMPORTANT REGIONAL ACTIVITIES
While much of OERR's communications with Regions will focus
on the areas described above, your continued attention to several
other program implementation goals is important. Headquarters
will continue its support to help achieve those goals. The
following list is intended to encourage the Regions to implement
new guidances or continue progress in the following areas:
Construction completions. Over 800 of the nearly 1300 NPL
sites have remedies under construction or are "construction
complete." OERR will continue to track construction
completions. OERR will assist the Regions by reviewing
- 6 -
-------
closeout reports and providing assistance in accordance with
the Construction Completions Care Package.
Community involvement. Communities should be involved
throughout the entire response process, for example in
developing land use assumptions. Several recently announced
reforms provide new opportunities to involve the public in
risk assessments and remedy decisions.
Partial deletions. A recent policy change (60 Federal
Register 55466, November 1, 1995) allows portions of sites
to be deleted before the remedy is completed for the whole
site. This tool may be useful in getting sites or portions
of sites back into productive use.
CERCLIS III. All Regions will begin using CERCLIS III
rather than CERCLIS II for program management activities by
early summer. By late summer, use of the system for all
Tier I data will expand to other Regional staff, e.g.,
remedial project managers (RPMs), on-scene coordinators,
site assessment managers.
Alternative approaches to site cleanup. Given the
limitations on site assessment and listing sites,
alternative approaches to site cleanup may be appropriate,
such as the use of voluntary cleanup programs, removal
authorities, and state authorities.
HEADQUARTERS CONTACTS
For more information on regional coordination and the focus
areas, please feel free to contact appropriate staff of the
Accelerated Response Center associated with your Region, as
provided in Attachment 2.
The following list provides a key to the attachments.
ATTACHMENT 1: REGIONAL COORDINATION FOCUS AREAS
1) Risk Management and Cost-effectiveness Decision
Documentation 1.1
2) Ground Water 1.4
- 7 -
-------
3) , Implementing Lead Policy
4) Presumptive Remedies....
1.7
1.10
ATTACHMENT 2: REGIONAL COORDINATORS..
2 .1
Attachments
cc: OERR Center Directors
OERR Senior Process Managers
Elaine Davies, OERR . ,
Larry Reed, OERR
Gershon Bergeisen
Jerry Clifford, OSRE
Jim Wool ford,. FFRRO
Kris Hoellen, ASTSWMO
Sharon Jaffess, Region 2, Co-chair, NARPM
Lesley Brunker, Pegion 3, Co-chair, NARPM
Jay Bassett, Region 4, Co-chai'r, NARPM
Shelley Brodie, Region 7, Co-chair, NARPM
Carl Pelligrino, Region 2, Chair, NOSCA
8 -
-------
ATTACHMENT Is REGIONAL COORDINATION FOCUS AREAS
1) Risk Management and Cost-effectiveness Decision Documentation
Why it is important:
Critical information. Risk and cost are two critical pieces
of information in deciding to take a response action,
determining the appropriate scope of the action, and
ultimately selecting the response action.
Criticism. Program decision making has been criticized.
This criticism may have been caused by our failure to
clearly explain the links between the risks present at sites
and the response actions taken to address them. Similarly,
the role of cost in our decisions may not have been
presented clearly. As a consequence, the program has taken
severe criticism for making decisions that are perceived as
not cost-effective. By focusing on improving the
documentation of the role risks and costs play in our
decisions, we hope to improve the transparency of our
decision-making and the public's trust in it.
Reauthorization. Both Congress and the Administration are
examining the role of cost in Federal remediation programs.
The reauthorization bills and EPA1s Superfund Reforms
reflect increased scrutiny of the role of cost'
considerations in the Superfund remedy selection process.
Consistent decision making and documentation of EPA's
response selection has become more important than ever.
Through this focus area we are highlighting the need to make
sound and transparent risk management decisions and to encourage
the proper documentation of those decisions, as well as the
information used to make those decisions.
Key Messages for Region Action:
It is very important that Regional risk assessor and risk
managers (RPMs and OSCs) discuss site issues and coordinate
efforts so that the response actions relate to the risks
found at sites.
- 1.1 -
-------
Clearly present risks that warrant action and clearly
demonstrate how the response will take care of these risks.
Decision documents (i.e., RODs and action memoranda) should
explicitly identify the risks that warrant taking an action
and how the remedy will address those risks, quantified to
the extent appropriate.
Use only reasonable exposure pathways for risk assessments.
While EPA remains committed to basing decisions on a
reasonable maximum exposure case, it is important to
remember that this is defined as the highest exposure that
is reasonably expected to occur. Look carefully at the
exposure pathways of'concern to ensure that the pathways
used to justify taking an action are reasonable (e.g.,
generally, residential land use of a landfill is not
reasonable unless that land use currently exists).
Clearly explain and clearly present the costs of the
selected response action and of alternative remedies
considered, and how the costs were balanced with other
tradeoffs in the presentation of the rationale for the
decision. These should include a thoughtful consideration
of long-term operations and maintenance (O&M) costs. It is
important that O&M costs are sufficiently considered so that
the States have a realistic understanding of the O&M costs
they will be assuming.
Clearly state the benefits. Although we perform cost-
effectiveness rather than cost benefit analysis in the
Superfund program, the decision document should clearly
identify the benefits of different alternatives in the nine
criteria analysis and the benefits of the selected response
action in the rationale for selection. Th'is includes the
risks and exposure pathways that will be addressed by the
remedy. Nonquantifiable benefits, such as reuse of
brownfields, should also be described.
EPA's effort to more clearly describe the role of cost does
not modify the already important role of cost in our
program. Rather, these activities emphasize EPA being more
- 1.2 -
-------
consistent and transparent when considering the costs of
cleanup actions and what they are accomplishing.
Headquarters Action Items:
Review proposed plans, as they become available, or draft
RODs to ensure that risk and cost data are clear and
presented in a consistent manner nationally, and that
decision rationales clearly discuss the role that cost and
consideration of benefits considered under the other
criteria played in the decision. Action memoranda for large
dollar removal sites will also be reviewed. Exposure
scenarios or risk assessment assumptions will also be
reviewed for appropriateness and consistency.
Provide advice and national perspective to the Regions in
the consistent implementation 01 guidance on presentation of
risk and cost information in decision documents for FY 1996
ROD decisions.
Continue the Interagency Workgroup on Cost-Effectiveness in
the Superfund Remedy Selection Process, which is developing
"rules of thumb" in this area (expected late in FY 1996).
Key Guidance:
"Interim Final Guidance on Preparing Superfund Decision
Documents," OSWER Directive: 9355.3-02 (EPA 624/1-87/001),
November 1989 (to be updated soon).
"Role of the Baseline Risk Assessment in Superfund Remedy
Selection Decisions," OSWER Directive 9355.0-30, April
1991.
New guidance resulting from Superfund Reform initiatives
should be available in the near future, and will include the
following:
- Role of Cost Directive,
Rules of Thumb, and
ROD Summary Sheet.
- 1.3 -
-------
2) Ground Water
Why it is important:
Large number of ground-water RODs. Ground-water RODs
have consistently made up approximately two-thirds of
the total RODs signed each year since the beginning of
the program.
Potentially high cost. Ground-water remedies vary
widely in cost, but can be quite high.
Controversy. Restoration of ground-water sites on the
National Priorities List can be time- and resource-
intensive. These issues have lead to Congressional
concerns about Superfund's 1) not matching cleanup
objectives with specific problems at sites; 2) alleged
inconsistent remedy selection among Regions and sites;
3) apparent lack of flexibility in remedy selection
process; and 4) incorporation of the latest
developments being out of step with the "science."
Key messages for Regional Action:
Always evaluate the likelihood of dense non-aqueous phase
liquids (DNAPL) presence;
Always consider use of a phased (sequential) approach to
remediation (i.e., early/interim actions preceding the final
action) to reduce immediate risks and to help assess the
long-term restoration potential of the site;
Always consider the sources of flexibility available in
ground-water remediation decisions: Technical
Impracticability (TI) ARAR waivers; longer remediation
timeframes; natural attenuation; Alternate Concentration
Limits (ACLs); and Ground-Water Classification/Future Use;
Use Comprehensive State Ground Water Protection Program
input if available to determine the classification of the
impacted ground water.
- 1.4 -
-------
Integrate the future land and ground-water use scenarios
into the overall site remediation objectives to ensure
compatibility.
Recognize that use of pump and treat remedies may still be
appropriate for achieving many remediation goals.
Headquarters Action Items:
Track number of remedy decisions employing phased approach,
TI waivers, natural attenuation, ACLs, and other sources of
flexibility.
Track estimated costs of ground-water remedies in RODs.
Consult with Regional staff on ground-water issues and
record the number and type of consultations.
Qualitatively evaluate level of awareness, interest, and use
of guidance in Regions.
Kev Guidance:
"Estimating the Potential for Occurrence of DNAPL at
Superfund Sites," OSWER Directive: 9355.4-07FS, January,
1992.
"Considerations in Ground Water Remediation at Superfund
Sites and RCRA Facilities-Update," OSWER Directive 9283.1-
06, May 1992.
"Guidance for Evaluating the Technical Impracticability of
Ground-Water Restoration," OSWER Directive 9234.2-25,
September 1993.
"DNAPL Site Characterization," OSWER Publication 9355.4-
16FS, September 1993.
New guidances under development that should be available in
the near future include the following:
"Presumptive Response Strategy and Treatment
Technologies for Contaminated Ground Water at CERCLA
Sites"
- 1,5 -
-------
"Consideration of 'Comprehensive State Ground Water
Protection Programs' by EPA Remediation Programs"
Useful Background:
"Guidance on Remedial Actions for Contaminated Ground Water
at Superfund Sites," OSWER Directive: 9283.1-2, December
1988.
"Considerations in Ground Water Remediation at Superfund
Sites," OSWER Directive: 9355.4-03, October 1989.
"Suggested ROD Language for Various Ground Water Remediation
Options," OSWER Directive: 9283.1-03, October 1990.
"Methods for Monitoring Pump-and-Treat Performance," ORD
publication EPA/600/R-94/123.
"Methods for Evaluating the Attainment of Cleanup Standards,
Volume 2: Ground Water," EPA/23 0- R-92-014, July 1992.
- 1.6 -
-------
3) Implementing Lead Policy
Whv it is important:
Frequently occurring. Lead is one of the most frequently
occurring contaminants at Superfund sites.
Large and potentially costly sites. Some types of sites
that typically have lead contamination (i.e., mining sites
and smelters) are very large, and cleanup level decisions
have significant cost implications.
Special methods developed. Special methods for considering
lead toxicity have been developed and must be followed.
Inconsistencies among sites. EPA has been criticized for
inconsistencies in setting site-specific lead cleanup
levels.
Technically and emotionally complex. Lead sites are
technically co-.plex and often have emotionally charged
communities. The many other potential sources of lead
contamination (pipes, lead-based paint) complicate the
issues, and may be beyond the scope of Superfund to address.
Key Messages for Regional Action:
Apply consistent methodology to set site-specific lead
cleanup levels. The IEUBK model should be used to assist in
developing a cleanup level for all response actions with a
residential land use, unless time limitations associated
with emergency or time critical removals prevents its use.
It should be used with as much site-specific data as
possible; at a minimum, soil and house dust must be included
in IEUBK application. Cleanup levels should be consistent
between the responses taken under removal and remedial
authority to the extent possible.
The OSWER Interim Soil Lead Directive (OSWER Directive:
9355.4-12, July 14, 1994) is the current guidance and
supersedes previous OSWER directives on lead in soil. A new
memorandum, "Administrative Reforms for Lead Risk
- 1.7 -
-------
Assessment" (April 17, 1996) outlines specific steps to
implement lead policy.
The Technical Review Workgroup of Headquarters and Regional
risk assessment experts provides assistance in implementing
the IEUBK model.. Pat Van Leeuwen (Region V, 312-886-4 904)
and Paul White (Headquarters, 202-260-2589) are the co-
chairs of the workgroup.
The 400 ppm screening level in soil is NOT A CLEANUP LEVEL,
but provides a screening level appropriate for children in a
residential setting.
A soil concentration of 1000 ppm is not a priori an
appropriate cleanup level for industrial sites. The
technical review workgroup can assist in developing an
appropriate industrial cleanup level as well as levels
associated with other land uses.
Factors such as lead species, chemical form, and
bioavailability may need to be considered when developing
risks and cleanup levels. For example, mining wastes may be
less bioavailable to children than other sources of lead.
Good site-specific information will be useful in determining
bioavailability, lead speciation, and specific chemical
forms.
The large scale of the problem at some sites will make
removal or treatment impracticable. Full soil removal may
not be appropriate, especially at large sites. Protective
remedies may include exposure intervention to ensure cost-
effective yet protective remedies.
Where there are multiple sources of lead, all sources of
lead should be considered in determining appropriate cleanup
responses.
Headquarters Action Items:
Identify lead sites and work with RPMs/OSCs to ensure that
they understand the issues.
- 1.8 -
-------
Review proposed plans to evaluate consistency with lead
policy.
Key Guidance:
Revised Interim Soil Lead guidance for CERCLA sites and RCRA
Corrective Action Facilities, OSWER Directive: 9355.4-12
(PB94-963282), July 14, 1994. This reference contains the
full reference for the IEUBK model and supersedes previous
OSWER lead guidances including Sept, 1989; May 9, 1990; and
June, 1990.
Guidance on Residential Lead-Based Paint, Lead Contaminated
Dust, and Lead-Contaminated Soil, (PB 94-962284), July 14,
1994. (This guidance from the Office of Toxic Substances
addresses lead paint hazards.)
Administrative Reforms for Lead Risk Assessment, April 17,
1996.
- 1.9 -
-------
4) Presumptive Remedies
Why it is important:
Streamlined Investigation. Presumptive remedies streamline
site investigations and speed up the remedy selection
process by reducing documentation and feasibility study
requirements.
Fewer Arguments with Stakeholders. In addition to
significant cost and time savings in the Rl/FS process,
Superfund stakeholders have indicated that by our clearly
presenting acceptable remedy preferences, there will be less
cause to argue over cleanup approaches. This will result in
better buy-in by states, local communities and PRPs.
Voluntary Cleanup. Certain presumptive remedies may also
promote more voluntary cleanups (e.g., manufactured gas
plants).
Streamlines remedial design. Additional savings can also be
realized in the design-phase, as presumptive remedies can
minimize or eliminate extensive data collection by
anticipating and supporting design needs during the Rl/FS
process.
Reform Initiative. Presumptive remedies have been
identified as both administrative improvements and reforms.
Key Messages for Regional Action:
Use presumptive remedy guidances at all sites where they are
appropriate. Presumptive remedy guidance is available for
municipal landfills, volatile contaminants in soil, and wood
treaters. User's Guides for RPMs are also available.
Involve stakeholders early (e.g., community, state and local
officials, site owners and/or potentially responsible
parties) to familiarize them with the concept of presumptive
remedies and how they will be used to streamline site
response.
- 1.10 -
-------
Establish future land use assumptions and protective cleanup
levels as part of the remedy selection process; they are
developed independent of the application of a presumptive
remedy. At specific sites, the need to achieve protective
levels consistent with anticipated land use may impact the
application of specific presumptive remedies (e.g.,
protective levels associated with residential land use may
preclude the use of biotreatment as one of the presumptive
. remedies at some woodtreater sites.
Recognize that some presumptive remedy guidances only
address materials comprising "principal threats," while
others are more comprehensive.
Headquarters Action Items:
Develop a questionnaire/survey instrument to evaluate the
implementation of presumptive remedies, both where they have
been used and where they should have been used but were not
used. This survey may be an electronic evaluation form for
use by site managers and may include telephone inquiries.
OSWER's Federal Facilities Restoration and Reuse Office will
address presumptive remedy use at Federal Facilities.
Track the implementation of presumptive remedies to ensure
consistent application of the guidance. Evaluations will be
performed and results circulated to communicate lessons
learned.
Monitor the potential application of presumptive remedies
through the CERCLIS III database.
Identify sites which should be employing presumptive
remedies. Inform those RPMs them about the use of the
presumptive remedy, and provide information on where they
can obtain additional guidance and support.
Key Guidance:
"Presumptive Remedies: Policy and Procedures," OSWER
Directive: 9355.0-47FS (PB93-963345), September 1993.
- 1.11 -
-------
"Presumptive Remedy for CERCLA Municipal Landfill Sites,"
OSWER Directive: 9355.0-49FS (PB93-963339), September 1993.
"Presumptive Remedies: Site Characterization and Technology
Selection for CERCLA Sites with Volatile Organic Compounds
in Soil," OSWER Directive: 9355.0-48FS (PB93-963346),
September 1993.
"Presumptive Remedies for Soils, Sediments and Sludges at
Wood Treater Sites," OSWER Directive: 9200.5-162
(PB95-963410), November 1995.
New presumptive remedy guidances under development that
should be available in the near future include the
following:
Presumptive Response Strategy and Treatment
Technologies- for Contaminated Ground Water at CERCLA
Sites
Manufactured Gas Plants
Sites Contaminated with PCBs
Grain Storage Sites.
- 1.12 -
-------
ATTACHMENT 2: REGIONAL COORDINATORS
REGION 1/9 ACCELERATED RESPONSE CENTER
REGION 1 REGIONAL COORDINATORS:
Mike Hurd. . . 703-603-8836
Charles Sands 703-603-8857
REGION 9 REGIONAL COORDINATORS:
Karen Bankert 703-603-9046
Alan Youkeles 703-603-8784
REMOVAL COORDINATORS:
Richard Jeng 703-603-8749
Art Johnson 703-603-8705
REGION 2/6 ACCELERATED RESPONSE CENTER
LEAD CONTACT FOR REGIONAL OPERATIONS
JoAnn Griffith 703-603-8774
REGION 2 REGIONAL COORDINATORS - REMEDIAL PROGRAM
Loren Henning. .703-603-8776
Marlene Berg 703-603-8701
Sherri Clark 703-603-9043
REGION 6 REGIONAL COORDINATORS - REMEDIAL PROGRAM
Matt Charsky (lead) 703-603-8777
Sherri Clark 703-603-9043
Karen Tomimatsu 703-603-8738
REMOVAL, SITE ASSESSMENT
Terri Johnson ..703-603-8718
EMERGENCIES/OIL/BUDGET/PROGRAM MANAGEMENT
Schatzi Fitz-James 703-603-8725
RISK ASSESSMENT, SITE ASSESSMENT
Janine Dinan 703-603-8824
ADMINISTRATIVE REFORMS
Mike Goldstein 703-603-9045
REMEDIAL DESIGN AND ACTION/O&M/RELOCATION/5 YEAR REVIEW
JoAnn Griffith 703-603-8774
-2.1-
-------
REGION 3/8 ACCELERATED RESPONSE CENTER
REGION 3 REGIONAL SUPPORT TEAM
EMERGENCIES/REMOVALS/OIL/ USCG
Roxanna Mero (lead) 703-603-9150
Anne Spencer (support) 703-603-8716
REMEDY SELECTION (includes RI/FS, RODs)
David Cooper (lead) 703-603-8763
Lisa Askari (support) 703-603-8799
Shahid Mahmud (support) . 703-603-8789
REMEDY IMPLEMENTATION (Design and construction)
Ken Skahn 703-603-8801
BUDGET
Anne Spencer (lead) 703-603-8716
Shahid Mahmud (support) 703-603-8789
Roxanna Mero (support) 703-603-9150
PROGRESS(SCAP, CERCLIS,Constuction Completion, etc.)
Rafael Gonzalez (lead) 703-603-8892
Susan Sladek (support) 703-603-8848
POST COMPLETION (5 YEAR, O&M)
Ken Skahn (lead) ..703-603-8801
Susan Sladek (support) 703-603-8848
REGION 8 REGIONAL SUPPORT TEAM
EMERGEN CIES/REMOVALS/OIL/USCG
Anne Spencer (lead).. 703-603-8716
Shahid Mahmud (support) .703-603-8789
REMEDY SELECTION (includes RI/FS, RODs)
Shahid Mahmud (lead) 703-603-8789
Lisa Askari (support) 703-603-8799
David Cooper (support) 703-603-8763
REMEDY IMPLEMENTATION (Design and Construction)
Rafael Gonzalez (lead) 703-603-8892
Ken Skahn (support) 703-603-8801
BUDGET
Anne Spencer (lead) 703-603-8716
Shahid Mahmud (support) 703-603-8789
Roxanna Mero (support).. 703-603-9150
PROGRESS (SCAP, CERCLIS,Constuction Completion, etc.)
Rafael Gonzalez (lead) 703-603-8892
Susan Sladek (support) . . J 703-603-8848
POST COMPLETION (5 Year review, O&M)
Ken Skahn (lead) 703-603-8801
Susan Sladek (support) 703-603-8848
- 2.2 -
-------
REGION 4/10 ACCELERATED RESPONSE CENTER
PRIMARY REGIONAL COORDINATION CONTACTS:
John Blanchard 703-603-9031
Dan Thornton 703-603-8811
Steve Chang 703-603-8758
Carolyn Kenmore 703-603-9033
Richard Troast.(ROD review lead)...703-603-8805
GENERAL EMERGENCY RESPONSE AND REMOVALS:
Terry Eby 703-603-8741
Greg Weigel 703-603-9058
REGION 5/7 ACCELERATED RESPONSE CENTER
EMERGENCIES/REMOVALS
REGION 5
Ernie Watkins... 703-603-9011
Duane Geuder. (backup) 703-603-8891
REGION 7
Awilda Fuentes 703-603-8748
Bonnie Gitlin (backup) 703-603-8868
EARLY ACTIONS
Ariarea McLaughlin. 703-603-8793
SITE ASSESSMENT
Scott Fredericks 703-603-8771
RISK ISSUES
Jack Arthur 703-603-9041
FS/ROD ISSUES (GENERAL)
Robin Anderson. 703-603-8747
GROUNDWATER
Ken Lovelace 703-603-8787
PRESUMPTIVE REMEDIES
Scott Fredericks (OERR lead) 703-603-8771
Andrea McLaughlin (munic. landfills) ... 703-603-8793
FOCUS AREAS REVIEW POINT OF CONTACT
Bonnie Gitlin 703-603-8868
(Specific sites will be assigned to other Regional Team
members)
- 2.3 -
-------
REMEDIAL DESIGN / REMEDIAL ACTIONS ISSUES
REGION 5
Awilda Fuentes 703-603-8748
REGION 7
Ernie Watkins 703-603-9011
NATIONAL REMEDY REVIEW BOARD
Bonnie Gitlin 703-603-8868
COST ESTIMATING
Tom Whalen 703-603-8807
OPERATIONS AND MAINTENENCE
Tom Whalen .703-603-8807
CONSTRUCTION COMPLETIONS
Awilda Fuentes 703-603-8748
U.S. ARMY CORPS OF ENGINEERS LIAISON
Bill Zobel 202-761-5517
BUDGET COORDINATION
Duane Geuder , 703-603-8891
QA/QC, DQOs
Duane Geuder 703-6 03-88 91
REPORTABLE QUANTITIES
Jack Arthur (lead) 703-603-9041
Dan Chellaraj (AARP) 703-603-8706
CONTINUOUS RELEASES
Bob Cattell (AARP) 703-603-9054
Stan Barkin (AARP) 703-603-8987
- 2.4 -
------- |