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• Attachment E 

### DEQ Site Screening for Assignment to Hazardous Waste or Cleanup (Draft)

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# • Site Screening forAssignmentto Hazardous Waste orCleanup
The following is a description of the process for determining which newly discovered or newly assigned sites from the ECSI Database will go to the Hazardous Waste Program (HW) for cleanup oversight, and which will go to the Cleanup (CU) Program. New sites will come to the attention of the department through staff in either the HW section or the CU Section. The specific staff will probably be field staff in the Site Assessment Section, Voluntary Cleanup Program or HW Compliance Section. They will be asked to review available information about the site to try to answer the following categories of questions. The questions are: HW Violations Has the facility been inspected by HW compliance inspectors and been found to be out of compliance? Have informal (Notices of Noncompliance) enforcement actions been issued? If so, how many? Have formal actions (orders, civil penalties) been issued? If so, how many, and have they been finalized, or are they still pending? Are they HPV? Has a criminal investigation been instigated? Has a HW technical assistance person or TUR TA provider visited the site? Did they discover "clear and immediate" environmental problems at the site? Past TSD History Has the site ever been considered to be a TSD (treatment storage, or disposal facility) in the view of the Department or EPA? Has the facility ever applied for a TSD permit application, or been an interim status facility, or had a permit denied? If yes, what is their current status? Are they operating under a current order? Past/CurrentGenerator History Has the facility operated or did operate gO-day hazardous" waste storage tanks that were notclean closed? Were the tanks clean closed? Type of Waste What is the waste that has contaminated the site? Is it a hazardous waste? Is it, or was . it, a listed waste? Is it a characteristic waste? (History of site concerning manufacturing



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• process, method of waste' generated when generating.) What are the levels of contamination? Volume of Waste How much waste was released or disposed of at the contaminated site? What is the estimate of the amount (volume) of contaminated material that will need to be remediated? The staff will also review the status of the site as to the existence of Regulated and/or Solid Waste Management Units (SWMUs) using the following description: HAZARDOUSWASTE MANAGEMENT UNITS (REGULATED UNITS): Regulated units include any of several possible "units" which are used to store, treat, or dispose of a hazardous waste and are subject to Subpart F groundwater monitoring, 

### '7 closure, post-closure permitting, financial assurance, and regulated unit corrective action under RCRA, such as:


## o Certain Tanks and Tank System Units 

## o ContainerStorage 

### o Surface Impoundments 

### o Waste Piles 

## o Land Treatment Units 

## o Landfills 

## o Incinerators 

## o Temporary Units (TU) 

## o Drip Pads 

## o Miscellaneous Units (SubpartX) 

## o Containment Buildings 

## o Underground Injection RCRA definitions and standards for all of these units can be found in 40 CFR 264. Type of units, number of units, variety of units, complexity of unit-rated issues, potential for clean closing units, are all factors that will determine which program takes the lead for a cleanup site. It is very importantto properly characterize regulated units. It is important to recognize that regulated units can be created. Typical examples of regulated units created in the course remediation include waste piles and processes used to treat hazardous waste containing media or groundwater

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• SOLID WASTE MANAGEMENT UNITS: Solid Waste Management Units (SWMUs) are similarto, and include, regulated units, butare where solid wastes have been managed. Technically, a Regulated Unit is a SWMU, but Regulated Units are subject to the closure, financial assurance and corrective action requirements listed above. SWMU corrective action was established when RCRA was reauthorized in 1984 as a special requirement at all facilities subject to RCRApermitting to address releases of hazardous constituents from all SWMUs on afacility-wide basis. The information summary generated by staff review for any specific site will be provided to a group consisting of HW and CU managers. The managers will use the included matrix"Preferred Site Lead/Regulated Authority" to determine the assignment of the site.

For any site that ends up in the part of the matrix marked "Joint Decision" the same manager group will use the information gathered about the site and the definitions described above to make the decision as to proper assignment of that site. GEH:djh/cmp x:\geh\site.ass

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DRAFT 

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PREFERRED SITE LEAD I 

### REGULATED AUTHORITY At Sites with Hazardous Waste Issues 

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Unknown!

Unable Operating TSD Subject to

Pennit, Includes Spills Systematic Disoharges of

Hazardous Waste Spills Resulting InHazardous Waste,

. Generation Noregulated units present