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Round 3-8: Consider Response Actions Prior to NPL Listing

Reform Description
This reform will provide greater flexibility to the current National Priorities List (NPL) policy for evaluating the impact of completed removals on the Hazard Ranking System (HRS) score by allowing consideration of some post-Site Inspection ("post-SI") completed removals in HRS scoring.

Based on experience with the current NPL policy, EPA recognized that some post-SI removal actions can substantially address the threat to human health and the environment, and should be considered up to the time of NPL listing. As a means of encouraging early response actions, especially by private parties, EPA can now consider certain post-SI removal completions (removals completed before the site is proposed to the NPL) when preparing HRS scoring packages.

This reform only applies to cases where an EPA Region clearly documents that there is no remaining release or potential for a release that could cause adverse environmental or human health impacts. Otherwise, the removed waste should be counted in the HRS waste quantity value calculation. If the site's HRS score drops below 28.5 as a result of these changes, and if all cost recovery activities have been addressed, the Region may archive the site from CERCLIS. The extent to which EPA applies this policy will depend on the facts of each case.

This reform:
  • Provides incentives for Federal agencies and private parties to conduct response actions and set priorities for listing sites on the NPL;

  • Reflects the Agency's priorities for listing only those sites adversely impacting human health and the environment; and

  • Reduces the Agency and private sector legal/transaction costs associated with the listing and subsequent process.

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Reform Status
check mark Implementation of this reform is complete.

EPA will continue to collect information and monitor implementation of the reform.

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EPA amended the October 1992 NPL policy in April 1997 (see Documents below). The Agency can now consider certain post-SI removal completions when preparing HRS scoring packages.

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Title: Revised Hazard Ranking System: Evaluating Sites After Waste Removals
Date: April 4, 1997
Document #: NTIS PB97-963215
Synopsis: This revision updates the October 1991 NPL policy on evaluating sites after waste removals. This policy allows EPA to consider certain post-SI removal completions (removals completed before the site is proposed to the NPL) in preparing HRS scoring packages.

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