1 MEMORANDUM | December 2, 2009

TO Terri Johnson, EPA

FROM Neal Etre, IEc

SUBJECT NPL Site QC Effort

NPL SITE QC EFFORT At the request of the Environmental Protection Agency’s Office of Superfund Remediation and Technology Innovation, I ndustrial Economics, Inc. (IEc) conducted a quality control (QC) effort to verify Nationa l Priorities List (NPL) site characterization information previously entered into th e Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS). Specifically, EPA requested that IEc:

• Confirm the Site Category and Site Sub category field entries (in general, these

entries identify the industry sector associated with the NPL site) by crosschecking site information.

• Suggest a correction for the Site Category and Site Subcate gory fields based on

our investigation. 1

• Locate, if possible, the last date of know n release associated with each NPL site.

If this date was not readily available, IEc identified the last date of known operation or the closing date for the facility.

• Match the confirmed/suggested Subcategory field with eight specific 3-digit

NAICS provided by EPA. We also identified facilities that conducted recycling operations. Below, we provide a bulleted list that describ es the data provided by EPA, along with the methods and caveats.

CERCLIS DATA

• The preliminary analysis was conducted on all proposed, final and deleted nonFederal Superfund sites as of August 5, 2009. In October 2009, IEc updated the database (and the analysis) to include recently listed, proposed, and deleted nonFederal superfund sites. Overall, we reviewed 1,633 records, which represent 1,495 proposed, finalized, and deleted non-fe deral NPL sites. Note that sites may have multiple site type/NAICS designations in CERCLIS.

1 In practice, the Category field does not provide useful info rmation and was often blank in the CERLCIS data pull. As a

result, and based on discussions with EPA, IEc spent relatively little effort to try to identify correctio ns for the Category field.• EPA also provided several spreadsheets that were produced by a similar QC effort conducted by EPA and IEc in April 2009. Where possible, we cross-referenced these spreadsheets with the CERCLIS da ta pull to obtain the most updated subcategory field as possible.

METHODS For each site (which may have contained multiple records) in the CERCLIS data, IEc attempted to confirm the Subcategory field using the information available on the Internet from NPL site facts sheets a nd related site documents (e.g., Records of Decision (RODs) and Remedial Investigation/Feasibility Studies (RI/FSs). 2

• For sites in which we determined that the Site Subcategory field contained an

error, we suggested corrections.

• For sites with multiple Subcategories entr ies, we examined each entry separately

and made suggestions accordingly.

• In addition, using the same sources, IEc attempted to identify the last date of

known release for each site. If we were unabl e to locate this date, we identified the date that the site ceased operations. This data search was conducted for all sites in the data pull, including tho se previously QC’d in April 2009.

• Given the quick turnaround nature of this effort and the large number of sites, IEc

limited the search for information for a particularly site to a maximum of 15 minutes. However, for some sites, we were able to confirm/find the information at faster rate.

• Using best professional judgment, a best match was found between the CERCLIS

site data and the definitions for th e eight NAICS codes provided by EPA, including:

o 325 Chemicals

o 331 Primary Metals

o 562 Waste Management

o 324 Petroleum

o 332 Fabricated metals (electroplating)

o 321 Wood Products

o 334 Computers/Electronics

o 812 Personal and Laundry Services (Drycleaning)

• In addition, EPA requested that we id entify “recycling” facilities. However,

recycling facilities do not have a designated NAICS code and can span a wide range of recycling operations. Recyclin g facilities were identified with a “REC” code in the database. Many of these sites were waste oil or oil recovery facilities.

2 For those sites previously QC’d in Apri l 2009, we did not QC the Site Subcateg ory, as this would have duplicated our previous effort.• For sites that did not match to th ese NAICS codes, we identified the confirmed/suggested Subcategory field.

• A final MS Access database containing the original CERCLIS data and updates,

along with data queries that provide IEc’s matches to the NAICS codes and Subcategories, was submitted to EPA on October 7, 2009.

CAVEATS TO THIS EFFORT

• The timeframe in which EPA requested this analysis to be completed required IEc

to make quick decisions to confirm or reject the Subcategory field entries for each site. While all due care was given to examine each entry, IEc had to make professional judgments regarding the accuracy of the Subcategory fields.

• The last date of known release was ofte n difficult to identify within the time

constraints. The documents examined rare ly specified this date with absolute certainty. At times, IEc had to infer the last date of known release from site descriptions and other information. Given the uncertainty with some of the dates, EPA should use this information cautiously.

• Where it was not possible to identify the l ast date of known release, IEc attempted

to identify the date when the facility ceased the operations that resulted in the NPL listing. In general, this date was mo re readily available within the time constraints; therefore, we are more certain of the ceased operations date than the last date of known release.