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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF
SOLID WASTE AND
EMERGENCY RESPONSE

NOV 2 9 2017

NOW THE
OFFICE OF LAND AND
EMERGENCY MANAGEMENT

OLEM Directive 9200.2-191

MEMORANDUM

SUBJECT: Geospatial Superfund Site Data Definitions and Recommended Practices

The purpose of this directive is to recommend national standards for the collection and
maintenance of geospatial data for Superfund sites, to be carried out by U.S. Environmental
Protection Agency (EPA) regional offices, with an expectation for data collection on proposed,
final and deleted National Priorities List (NPL) and Superfund Alternative Agreement sites.
Collection of geospatial Superfund site data that follows these standards promotes EPA's ability
to share information with the public and to perform analyses to support program implementation
and evaluation in a consistent fashion. Generally, these data should be collected and made
available strictly for informational purposes.

This directive does not currently extend to time-critical removal actions and emergency response
activities. The removal program will work toward developing a concurrent process that comports
with this directive to ensure programmatic consistency and continuity.

FROM: James E. Woolford, Director

Office of Superfund Remediation and Technology Innovation

TO:

Superfund Division Directors, Regions 1-10

PURPOSE

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Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable * Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper


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BACKGROl M>

i he Office of Superfund Remediation and i echnolog\ Innovation (OSR i i) and the Federal
I acilities Restoration and Reuse OH ice (i'TRRO) have developed a set of'definitions for the
purposes of this document and recommended practices for data collection to help promote

routine and consistent collection of site geospatial data. EPA currently collects such data for
man)1 Superfund sites, but much of ihis information is not widely available in electronic format
at the national level. Specifically, this directive's objective is to help promote consistency in the
collection and sharing of site- and operable unit- (01 ) level data as well as other site-related
geospatial data, such as the location of institutional controls (ICs) and the extent of
contamination. l)escripli\e geospatial data generalK should be collected and updated using clear
and consistent definitions, as defined for the purposes of this document below, throughout the
Superfund life c\elc. and this information should he preserved as par! of the site records,

Geospatial data, as they relate to Superfund sites, may include point data (latitude/longitude),
lines, arid/or polygons representing some site-related area of interest. Examples of point data
include points representing a site's center, an entrance or other relevant features, such as building
locations. In contrast, polygons may represent a site's perimeter, an individual OU's perimeter,
areas covered by it's or documented areas covering a release's known extent of contamination.
While a single point may he the only a\ailable geospatial information earh in the Superfund
process, detailed site maps, depicting polygons for a site's perimeter, area of contamination and
(>1 s. generally should all be available by the time IJ'A issues a Record of Decision (ROD) for a
remedial action or signs an Action Memorandum (AM) for a Non-Time-Critical Removal
Action, and. potentially, much earlier. Proactive and early collection of geospatial data is
beneficial because it may facilitate investigational activities, communication, and decision
making processes. As site characterization and cleanup progress, modification to this geospatial
information may be necessary.

Superfund site geospatial data may be used for many purposes, both internal and external to the
I J'A. Hxternally. they can provide useful community-specific information to the public on hPA
activities and the location of key site attributes. Internally, geospatial information can support

analyses, such as the health and ecological impacts of cleanups, site characterization, emergency
planning and cross-program collaboration.

KK( OMMENDi-1) l>KAC TICKS

( ollecting (Geospatial Data:

Site geospatial data evolve and may be refined during a site's liSi-cycle I liese data generally

should be collected and maintained throughout the Superfund process, and as site data are
refined, updated data should be collected as they become available. Typically, geospatial data are
collected throughout the lifecyele of a site, and eventually may become part of the administrative
record. See 40 C.F.R. § 300.810(a)(1).

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Il is important thai Supcrfund gcospatial information be collected and retained in a manner thai is
consistent with both federal and EPA standards and procedures. Please refer to the joint OSRT1
and Office of Site Remediation and Enforcement (OSRK) guidance, " !

iL"v '< I1,;! hi; ! >,~!.; . t! I • i I I ^ '' T C ^ ii" ? V ; i p < ¦:' { !t i! U"	I -i " .1,1' id! ' '1 k'! i J ->1< >*t r,; {_ ! R( 1

M.r 'in. - u' A >n. " (September 29, 2014) containing model language for collection and
electronic submission of geospatial data. In addition, the Office of I.and and Emergency
Management (OLIiM) is developing an OLEM geospatial technical resource document to
describe recommended practices for OLEM program offices" data capture activities. When this
resource becomes available. EPA regional Supcrfund program offices mas use it as a guide when
undertaking site data eollection and retention activities.

While EPA docs its best to ensure high quality geospatial data, the agency generally does not
vouch for data accuracy, completeness or currency. EPA also does not independent!) \erif\ data
provided bv external parties, EPA reserves the right to revise Supcrfund geospatial data at am

time. A data disclaimer is provided at the end of this document.

(n'eospatiai Definitions, for purposes of this guidance:

Supcrfund geospatial data may either be point data (latitude and longitude coordinates) or
polygons, depending on the feature being represented and the information available at the time of
data collection, (ieospatia! data should be collected concurrently with descriptive metadata.

Please sec the attachment for expected metadata fields, as described in the forthcoming OLEM
technical resource document.

Point Data (Coordinates): The Supcrfund program primarik uses point data to identil) a site's
initial location when EPA adds a new site to the Supcrfund Enterprise Management System

(SliMS) active site inventory. Section V.E of the fisoL Year 2
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•	Operable Unit Polygons: The OU polygons represent an individual OU's perimeters, which
are used to identify a portion of a Superfund site with which assessment and response actions
are associated. CHRCLA regulations (40 C.F.R. § 307.14) define an OU as a "discrete
portion of a remedial response [that} manages migration, or eliminates or mitigates a
release, threat of release, or pathway of exposure The cleanup of a site can he divided into a
number of operable units . . . [that] may address geographical portions of a site. "

Determined on a site-specific basis. OlJs may represent distinct geographic areas, media or
releases. Note that OUs may overlap geographically when representing distinct media or
areas of concern.

•	1 otal Site Polygon: The total site polygon represents the footprint of a whole site, defined for
purposes of this document as the sum of all of the OUs and the current understanding of the
full extent of contamination. For Federal Facility sites, the total site polygon may be the
Facility boundary. As site investigation and remediation progress. OUs may be added,
modified or refined, and the total site pohgon should be updated accordingly.

Polygons may also represent other important site features:

•	Institutional Controls: As discussed in existing UPA CFKCFA guidance, institutional
controls (ICs) are:

Non-engineered instruments, such us administrative and legal controls, that help to minimize
the potential for exposure to contamination and/or protect the integrity of a response action.
ICs typically are designed to work hy limiting land and/or resource use or by providing
information that helps modify or guide human behavior at a site ("institutional Controls: A
Guide to Planning. Implementing.. Maintaining and Enforcing Institutional Controls at
C \>niamii Kited .Sites:" Office of Solid Waste and Emergency Response JOSW'liR] Directive
9355.0-89: December 2012).

Generally, an IC polygon should represent the perimeter of an area subject to site ICs. 1 he
collection of geospatial data about the location of ICs is recommended whenever practicable.
The IC polygon name should be the same as the IC names entered into SUMS, and the
polygon description should match the IC type specified in SHMS.

•	Uxtent of Contamination: Polygons of a site's extent of contamination represent areas of
contaminated media, as identified during site investigations and as refined as the cleanup
proceeds. See Guidance for Conducting Remedial Investigations and Feasibility Studies
under Cl KCi A (OSWHR Dir. 9355.3-01. Oct. 1988). These polygons are based on the best
available data at the time they were created, and are subject to change or further refinement
as contamination is found and as cleanup takes place. Polygons should be submitted/updated
when possible at major milestones of site contamination definition. Previous polygons should
be retained for historical purposes.

•	Uninnccrintz Controls: Hngineering controls (HCs) include physical structures and barriers
(e.g.. fences, walls, gates, caps) that prevent exposure to contamination. UC polygons may-
represent the location of specific KCs, such as the perimeter or a cap or fence line boundaries,
but may also be captured as points (e.g., a gate) or lines (e.g.. a fence), as appropriate.

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• Reuse/Continued Use: In existing HP A t'HRCLA guidance. "Reuse" is discussed as an area
where "'a new use. or uses, are occurring such that there has been a change in the type of me
(e.g., industrial to commercial), or the property was unused and «mr supports a specific
use." The agency refers to "Continued i ^se" as areas thai "are being used in the same general
manner as they ivcre when the site became subject to the Super fund or federal Facilities
programs" (FYJlifl 7.SPI\!,), A reuse/continued use polygon may represent the perimeter of
an area identified as being reused or in continued use. The reuse polygon name should be
consistent between the polygon and the data siored in SI;MS.

In addition to points and polygons, lines may be used to represent site features, such as fences,
pipes or utilities.

I inderstanding that there may he some sensitivity issues with releasing eertuin types of
geospatial data, regions may flag data for internal use onh. Regions are still encouraged to

eolleet these data for internal record keeping and analyses.1

3 Freedom of Information Act (FOIA) discovery and federal records management requirements would still apply to
these internal data.

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Table 1: Key Types of Geospatial Superfund Site Data

(>cospatial

Information

Primar} Site
Location

Type of Data

Point

May Be Initially
Determined by:

Pre-CLRCLA Screening,
Preliminary Assessment/Site
Inspection (PA'Sl). N 1*1 - Listing

Potential Milestones to Prompt
Update:

Additional site assessment work.
Remedial Investigation (RI)
Hngineering Hvaluation Cost Analysis
(Lh CA)

Operable Units

P«K b!OT3

RI Et, CA, Federal Facility
Agreement (including but not
limited to). Site Management
Plans

Additional Ri/Eti.CA work. Record of
Decision (ROD). Action Memorandum
(AM). ROD/AM Amendmerits.
Explanation of Significant Differences
(LSD). Remedial Design (RD). Remedial
Action (RA) Completion. Partial
Deletion

Total Site Polygon Polygon
(ail OUs)

Rl.kiF CA. Federal Facility
Agreement (including but not
limited to). Site Management
Plans

Additional RI !•)• ( A work, RODs AMs.
ROD.. AM Amendments. LSDs. RD. RA
Completion. Deletion

Institutional
Controls

Lxtcnt of
Contamination

Engineering
Controls

Continued
Use/Reuse

Point. Line or
Poh non

Polygon

Point. Line or
Polygon

Polvnon

ROD/AM. ROD'AM
Amendment. LSD. Letter to the

file

RI/LLCA

ROD/AM, ROD/AM
Amendment. LSD, RD/RA.
Letler to the file
Defined throughout lifecycle of
site

RODs AMs. ROD'AM Amendments.
LSDs. creation of an iCs Implementation
and Assurance Plan (IC'IAP), letter to the
flic, implementation of a new IC
instrument

Additional RIT.L'CA work, RODs. AMs.
ROD'AM Amendments. ESDs. RD. RA
Completion. Deletion

RODs'AMs, ROD/AM Amendments.
LSDs. Letter to the file

L'pdated as needed

Site Geospatial Lifecycle;

Regions may submit geospatial data as they become available but at minimum, data should be
collected when a site reaches certain cleanup process milestones. Recommended practices for
generation of geospatial data are outlined below.

Highest Priority:

• Primary Site Location Data should be recorded and entered into SHMS as part of the Pre-
CLRCLA screening (PCS) checklist/decision form (OLKM Directive 9200.3-107). Point data
may be improved, refined or corrected as data become available.

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•	Operable link Polygons should be entered into SI-MS when EPA issues a ROD (or AM) to
address a corresponding GU, but regions are encouraged to enter them earlier in the
Superfund Hiceyele.

•	Total Site Polygons may represent the sum ol'the ()l !s or the extent ofthe Federal Facilities
Agreement, and their entry into SI-MS is recommended to be done concurrently with a
ROD's for ANTs) publication. Regions are encouraged to submit total site polygons early in

the Superfund process, and update them as they change, but a preliminary site polygon
should be captured no later than the completion of the first ROD (or AM) associated with a
site.

Additional information, in order of priority for collection, when available:

•	Institutional Controls location data should he captured when ICs are implemented.

•	Extent of Contamination polygons, while sometimes difficult 10 define and subject to

revision, are valuable information, which regions are encouraged to share when possible.
Typically, these data would be defined during the Rl and would be entered into SEMS after
the R! (or EE/CA) is approved.

•	Engineering Controls location data may be captured when ECs are implemented.

•	Continued Use/Reuse PoKtions may be entered into SEMS concurrently with the
identification of continued use and/or determination of acres ready tor reuse.

To ease collection and submission of gcospatiai data, regions are encouraged to require

electronic submission of geospatial data as part of enforcement agreements with potentially
responsible parties and in statements of work (SOWs) for site-specific contract work. Please see
the joint OS WEK/OSRE memorandum "i	Mo.ivl *	! K-.u ana 1 Lvu.t.k

N H"	Ti t,: : K ii. i r_i' ¦ ic- !	! jm- n 'n t i Rf. \ ^ic.-1-' • >; . r\"

- [-uimI-.li _ .1 i" for appropriate model language for enforcement documents and contracts.

Updating and Rev ising (ieospatial I) it i

Accurate data are desired lor all remedial sites that have a ROD, but this information may not be
readily available in electronic format for all sites, and so the regions generally should prioritize
obtaining this information as it becomes available. Site milestones, such as five-year reviews,
ROD amendments or explanations of significant differences, may present opportunities to collect
new, and update existing, site geospatial data.

Submission of (ieospatiaJ Data to Headquarters:

1 Mtimately. the Superfund Enterprise Management System (SEMS) will be the repository for
linking Superfund geospatial data, metadata and vintage information to the Mte-specific data as

well as storing and providing access to this information. However, because the modifications
required for SEMS to appropriately store and distribute geospatial data arc non-trivial, OSRT1 is
taking a phased approach, initially focusing on assisting the regions with development of

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regional geodalabases that are synchronized with SEMS data and fed into an Ef A enterprise
geospatial framework.

Responsibilities as part of this initial phase are proposed as follows:

•	Regions will be responsible for creating and maintaining regional geodatabases,
following a standardized schema (see attachments). To assist in this process. Regions 2
and 8 have developed a template that will be made available al
https://usepa.sharepoint.com/sitcs/oei/GlS WORKGROUP/.

•	The SUMS team will develop web services to allow joining of attributes and data
synchronization between the regional geodatabases and SEMS.

•	A process will be developed for the regional geodatabases to use the SHMS web service
and to be harvested and merged into national data sets residing on the Shared Enterprise
Geodata and Services (SHGS) servers.

•	The Shared Enterprise Geodata and Services (SEGS) will create national geospatial web
services from the data layers residing on an EPA enterprise geospatial framework that
can be used by other EPA data systems and applications such as the EPA GeoPiatform
Online (GPO). the Environmental Dataset Gateway (EDG). the Facilit) Registration
Service (FRS) and Cleanups in My Community (CIMC).

The planning, design and implementation of a national solution in SEMS is a priority and will
include representatives from all stakeholder groups and will coordinate closely with the EPA
National GIS Workgroup.

Collection of Federal Facility Data:

Regions are encouraged to work with their Federal Agency counterparts to collect Federal
Facility total site polygons (Facility boundary ) and Operable Unit (OU) polygons. If data arc
received from another Federal Agency. States, or third parties such as potentially responsible
parties or contractors, regional staff should work with the dataset to conform to the guidelines
outlined in this directive, the :	¦	¦	¦ =. v ~	-

\ " J ! - ¦ -	; • - ¦ - ' ¦ (September 29. 2014)

document and attachment and any OEEM technical resources guides that become available to the
extent practicable.

Disclaimer:

When Supcrfund geospatial data are shared internally or with the public. OSRTI recommends the
following caveat be included:

J he Agency is providing this geospatial information as a public service
and does not vouch for the accuracy, completeness or currency of data.
Data provided by external parties is not independently verified by EPA.
These data are made available to the public strictly for informational
purposes. Data do not represent EPA \s official position, viewpoint or

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opinion, express or implied This information is not intended for me in
establishing liability or calculating Cost Recovery Statutes of Limitations
ami cannot be relied upon to c reate any rights, substantive or
procedural, enforceable by any party in litigation with the f 'nited States
or third parties. EPA reserves the right to change these data at any time
without public notice.

1 his directive and its attachments are intended as guidance for EPA employees. It is not a rule
and does not create any legal obligations. Consistent with EPA s Guidelines for Hnsurirm and
.VkixjmiVini; the .Quajity, Objectivity. Utility and Integrity of Information Disseminated bv 1 he
DxGrnnmental Protection Agency (EPA/260R-02-00X. October 2002), EPA will include the
above disclaimer to notify users of the status of tile data and that its distribution does not support
or represent ofllcial Agency \ie\vpoints.

CONCLUSION

Geospatial data relating to Superfund sites serve important internal and external purposes that are
furthered by gathering and maintaining these data in a nationally consistent manner. If you have
any questions or concerns about the information in this directive, please have your staff contact;
Alicia Frame, Julia Field or Jennifer Sutton for OSRT1 data, John Burchette for I FRRO data, or
direct your inquiries and feedback to 1>sR M t, lis <,* ci'a. ;
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ATTACHMENTS
Attachment A - Metadata Definitions

Metadata Fields, as excerpted from the forthcoming OLEM geospatial technical guidance:

Field Name

Description

EPAJD

Assigned EPA program site identification number.

POINT_GEOMETRY

ESRI Feature Class or equivalent Oracle Spatial binary
format, projected in WGS84,

POLYGON_GEOMETRY

PQINTTYPE

Total Site, Operable Unit, Institutional Control, Extent of
Contamination, Engineering Control, Use/Reuse, or
Other.

POLYGON_TYPE

POINT_NAME

A descriptive title for the data may in some cases
duplicate the feature type, but should indicate the type of
feature especially if the type is "other." Example names
include Site, OU, Extent of Contamination, Institutional
Control, Engineering Control, Facility, Storage tank. Utility
corridor, Adit, Berm, Cap, Clean-up area. Cultural
resource, Ditch, Excavation, Impoundment, Lagoon, Pile,
Pit, Pond, Surface mine. Waste in place. Waste treatment
unit, Well.

POLYGON_NAME

POLYGON_DESCRIPTION

Create a short narrative description of the line. For
example, explain how the polygon may include property
boundaries, extent of contamination, or observance of
geographic boundaries such as streams.

COLLECTION„DATE

Date the information was collected.

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TIER_ACCU RACY_COOE

This dropdown supplies the Tier number to the system
{values 1 - 6 used for cleanup sites in both programs).1

HQR1Z_COLLECT_METHOD

The collection method implies the accuracy tier for the
measurement.2

HORIZ_ACCURACY_MEAS

Specific accuracy for this measurement in meters, if
available.

HORIZ„REFRNC_DATUM

Select from dropdown. POINT_COLL_METHOD. Values
can include NAD83, WGS84. Any measurements in NAD27
should be converted to WGS84.

POINT_INFO_URl

A URL to an address that documents the polygon feature
in more detail.

POLYGONJNFOJJRL

POINT_INFO_URL_DESC

A very short description of the URL, such as the name of
the system (e.g., SEMS, RCRAInfo) or the content of the
URL target (e.g., Institutional Control)

POLYGOISI_INFO_URL_DESC

HAS _CONTROL

Flag for whether the feature includes at least one
Boundary Control, either Institutional or Engineering.

CONTROL_TYPE

If the feature has a polygon control (EC or IC) specify the
type of control: values are Enforcement & Permitting
Tools (EP); Government Control (GC); Proprietary Control
(PC); Information Device (ID); Groundwater Control (GW);
Non-Groundwater Control (NG).

REGION AL_SUPP_CONTROLJ D

This is an optional field to receive supplemental regional
IDs that may be developed for the Long Term
Stewardship program or other functions.

CONTROL_DESC

Briefly describe the Control.

1Tier Accuracy is described in the National Geospatiat Data Policy (NGDP), CIO Policy Transmittal 05-002,

https://www.epa.gov/Keospatiai/epa-national-geospatial-data-policv
2 Ibid.

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CONTROL_URL

URL of the document(s) defining the Point Control. This
may be a pointer to SEMS RM, a Drupal page of RCRA CA
documents or some other repository.

CLEARED_PUBLIC_RELEASE

(Y/N) flag indicating if the feature is cleared for public
release via associated web services. Default would be Y.
Features not cleared for public release would be available
to internal EPA staff via the intranet GeoPiatform or other
internal platforms.

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Attachment B - Geospatial Dataflow Schema

Figure 1: Geospatial Data Flow Schema

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