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Environmental Epidemiology, Volume 1: Public Health and Hazardous Wastes (1991)
Commission on Life Sciences (CLS)

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. "2. State and Federal Context for Environmental Epidemiology of Hazardous Wastes." Environmental Epidemiology, Volume 1: Public Health and Hazardous Wastes. Washington, DC: The National Academies Press, 1991.

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ENVIRONMENTAL EPIDEMIOLOGY: Volume 1

ticipation with EPA regional staff in the scoping phase of Superfund remedial investigations—during which both the sampling plans and the preliminary remedial goals are established—will be tested at six sites during FY91 (H. Emmett, ATSDR, personal communication, 1991). As ATSDR has cleared the backlog of health assessments on preexisting NPL sites, moreover, an important role has emerged for ATSDR's health assessments in the selection of remediation strategies by EPA. The preliminary health assessment is initiated by ATSDR when EPA proposes a site for NPL listing in the Federal Register, that is, after the EPA preremedial evaluation has been completed but well before the RI/FS begins (the RI/FS frequently does not begin for another four to five years). Under these conditions the health assessment becomes the main evaluation of the public health impact of a site proposed for NPL listing, and this information is directly available to the community, to policy makers, and to research scientists, including environmental epidemiologists.

Although the full ATSDR health assessment is not completed until the RI/FS has been concluded, the preliminary health assessment attempts to cover much of the same ground with the data at hand. ATSDR's deputy administrator has argued that the agency's assessments need to draw on more information about the health concerns of the community and local health care providers (Johnson, 1990). This is particularly important because ATSDR increasingly functions as a “communication ” arm of the Superfund program with concerned communities. Finally, ATSDR is now compiling the results of the more than 1000 health assessments completed to date at NPL sites to create a data base of health-related information. This data base will be used to identify patterns of hazardous-chemical releases from particular types of sites and to identify those releases most frequently found among all sites (ATSDR, 1989a).

DEFERRAL OF SITES AND NFRAP DESIGNATION

Sites submitted to the Superfund program for initial entry in the CERCLIS inventory can be rejected and deferred to the responsibility of other federal or state agencies that have jurisdiction. A site that enters the CERCLIS inventory can subsequently be designated “no further remedial action planned” (NFRAP) if it is determined to be outside Superfund jurisdiction or if its projected HRS score is too low for proposal for NPL status. Superfund responsibility for the site is then terminated. In most cases responsibility for these sites reverts to the states, although it can revert to another federal agency, such as the Department of Defense or the Department of Energy. Because

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