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Screenings and Preliminary Assessments
SCREENING
Screening is the DEQ Cleanup Section's initial evaluation of sites
that have been added to the agency’s Environmental Cleanup Site
Information system. (ECSI is DEQ’s electronic database of
sites with known or suspected hazardous substance contamination.)
DEQ adds sites to ECSI based on information from a variety of
sources, including referrals from other programs, spills,
complaints, and unsolicited reports, as well as from Site Assessment
staff’s discovery of sites that may present significant threats to
human health or the environment. Site screening is designed to:
- determine whether a release of a hazardous substance has
occurred or could occur;
- determine whether site contamination poses or may pose a
significant threat to human health or the environment;
- determine what further actions are needed at a site, and the
priority for those actions;
- document Site Assessment’s decision-making process; and
- provide information for updating the ECSI database.
There are six general actions associated with a site screening, as
explained below:
- Gather available site data. Site Assessment staff first review
readily available information from internal DEQ files, U.S. Geological Survey
topographical maps, and other agencies. Then, to obtain additional
facility data, staff normally send an information request letter to
the site owner or operator. Tailored to the site, this letter may
request site investigation or cleanup reports not in DEQ files,
information about disposal of hazardous substances used or generated
at the facility, details on historic or current facility operations,
and other related information.
- Evaluate site information; develop and document conclusions.
Site Assessment’s standard screening write-up is called a Strategy
Recommendation, which addresses site history and contamination
issues, highlights likely pathways of exposure, presents DEQ’s
recommendations for further action (if any- sometimes screenings
result in no-further-action determinations), and lists
references. For sites needing further actions, the Strategy
Recommendation indicates the priority for those actions (see item #3
below). The Strategy Recommendation also presents a listing
recommendation (see item #4 below).
- Assign a priority for further site action(s). Using DEQ’s Site
Assessment Prioritization System, or SAPS, staff determine the
priority – low, medium, or high – for further actions needed. SAPS
integrates many features associated with the site, and gives a final
"score" that Site Assessment staff use in assigning a site priority.
The priority given depends on information, such as:
- manner of release and media affected by hazardous
substances;
- approximate volume(s) of contaminated media at site;
- toxicity and water solubility of contaminant(s) of concern;
- groundwater depth and main uses of groundwater within 2
miles of the site;
- distance to the nearest recorded drinking water well;
- distance to surface water, and main uses of surface water
within 2 miles of the site;
- permeability of surface and near-surface soils;
- main land uses within ½ mile of site;
- site’s proximity to defined Sensitive Environments [Oregon Administrative Rules
340-122-115]; and
- likelihood of human direct contact with hazardous
substances.
- Make a listing recommendation (i.e., should the site be added to
the Confirmed Release List or Inventory?). If a hazardous
substance release has been documented, the site may qualify for the
CRL. The site may also qualify for the Inventory, if a release has
been documented and a PA or PA Equivalent has been completed. (See
below for a discussion of PAs and PA Equivalents.) If a site is
eligible for either the CRL or Inventory, state law obligates DEQ to
pursue listing as a way to notify the public of contaminated sites.
CRL or Inventory listing is not meant to assign cleanup liability to
specific persons or companies.
- Update ECSI. When the screening is final, Site Assessment staff
update the ECSI database with information on site contamination
issues, concentrations of hazardous substances in various media (if
data is available), recommended further actions (including CRL/Inventory
listing recommendations), and site priority. A primary objective of
updating ECSI after a screening is to provide, for other DEQ staff
and the general public, a concise and current summary of site issues
and the human health or the environmental threats the site may pose.
- Notify owner/operators of screening results and conclusions. To
complete the screening, Site Assessment staff send a letter to
responsible parties describing what further actions are needed
and under what priority. This letter is often referred to as an
"options letter," because it lays out several choices available to
RPs. For low- or medium-priority sites, DEQ usually gives RPs three
options: 1) pursue further action under DEQ’s Voluntary Cleanup
Program; 2) implement further actions independently (i.e.,
without VCP oversight); or 3) take no action and wait for DEQ to
take the next step. For high-priority sites (where risks to human
health or the environment are considered imminent or substantial),
DEQ may limit RPs’ options so that the agency retains more control
over the nature and timing of remedial actions. A
"no-further-action" letter is another possible outcome of a
screening.
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