United States
Environmental Protection
Agency
Solid Waste
and Emergency Response
(5306W)
EPA530-F-97-001
July 1997
Landfill Reclamation
his fact sheet describes new and innovative technologies and products
that meet the performance standards of the Criteria for Municipal Solid
Waste Landfills (40 CFR Part 258).
Landfill reclamation is a relatively new approach used to expand municipal
solid waste (MSW) landfill capacity and avoid the high cost of acquiring addi-
tional land. Reclamation costs are often offset by the sale or use of recovered
materials, such as recyclables, soil, and waste, which can be burned as fuel.
Other important benefits may include avoided liability through site remediation,
reductions in closure costs, and reclamation of land for other uses.
Despite its many benefits, some potential drawbacks exist to landfill reclama-
tion. This technology may release methane and other gases, for example, that
result from decomposing wastes. It may also unearth hazardous materials,
which can be costly to manage. In addition, the excavation work involved in
reclamation may cause adjacent landfill areas to sink or collapse. Finally, the
dense, abrasive nature of reclaimed waste may shorten the life of excavation
equipment. To identify potential problems, landfill operators considering recla-
mation activities should conduct a site characterization study.
Landfill reclamation projects have been successfully implemented at MSW
facilities across the country since the 1980s. This fact sheet provides information
on this technology and presents case studies of successful reclamation projects.
The Reclamation
Process
Landfill reclamation is conducted in a num-
ber of ways, with the specific approach based
on project goals and objectives and site-
specific characteristics. The equipment used
for reclamation projects is adapted primarily
from technologies already in use in the min-
ing industry, as well as in construction and
other solid waste management operations. In
general, landfill reclamation follows these
steps:
Excavation
An excavator removes the contents of the
landfill cell. A front-end loader then orga-
nizes the excavated materials into manage-
able stockpiles and separates out bulky
material, such as appliances and lengths of
steel cable.
Soil Separation (Screening)
A trommel (i.e., a revolving cylindrical sieve)
or vibrating screens separate soil (including
the cover material) from solid waste in the
excavated material. The size and type of screen
used depends on the end use of the recovered
material. For example, if the reclaimed soil
typically is used as landfill cover, a 2.5-inch
screen is used for separation. If, however, the
reclaimed soil is sold as construction fill, or
for another end use requiring fill material
with a high fraction of soil content, a smaller
mesh screen is used to remove small pieces of
metal, plastic, glass, and paper.
Trommel screens are more effective than
vibrating screens for basic landfill reclama-
tion. Vibrating screens, however, are smaller,
easier to set up, and more mobile.
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This planning sequence assumes
that project planners will make an
interim assessment of the project's fea-
sibility after each planning step. After
completion of all five steps, planners
should conclude the feasibility assess- -
ment by weighing costs against bene-
fits. A thorough final assessment
should include a review of project goals
and objectives and consideration of
alternative approaches for achieving
those ends.
Conduct a Site
Characterization Study
The first step in a landfill reclamation
project calls for a thorough site assess-
ment to establish the portion of the
landfill that will undergo reclamation
and estimate a material processing rate.
The site characterization should
assess facility aspects, such as geological
features, stability of the surrounding
area, and proximity of ground water,
and should determine the fractions of
usable soil, recyclable material, com-
bustible waste, and hazardous waste at
the site.
Assess Potential
Economic Benefits
Information collected in the site char-
acterization provides project planners
with a basis for assessing the potential
economic benefits of a reclamation
project. If the planners identify likely
financial benefits for the undertaking,
then the assessment will provide sup-
port for further investing in project
planning. Although economics are like-
ly to serve as the principal incentive for
a reclamation project, other considera-
tions may also come into play, such as
a communitywide commitment to
recycling and environmental manage-
ment.
Most potential economic benefits
associated with landfill reclamation are
indirect; however, a project can gener-
ate revenues if markets exist for recov-
ered materials. Although the economic
benefits from reclamation projects are
facility-specific, they may include any
or all of the following:
• Increased disposal capacity.
• Avoided or reduced costs of:
—Landfill closure.
—Postclosure care and monitoring.
—Purchase of additional capacity or
sophisticated systems.
—Liability for remediation of sur-
rounding areas.
• Revenues from:
— Recyclable and reusable materials
(e.g., ferrous metals, aluminum,
plastic, and glass).
— Combustible waste sold as fuel.
—Reclaimed soil used as cover
material, sold as construction fill,
or sold for other uses.
• Land value of sites reclaimed for
other uses.
Thus, this step in project planning
calls for investigating the following
areas:
• Current landfill capacity and project-
ed demand.
• Projected costs for landfill closure or
expansion of the site.
• Current and projected costs of future
liabilities.
• Projected markets for recycled and
recovered materials.
• Projected value of land reclaimed for
other uses.
Investigate Regulatory
Requirements
Landfill reclamation operations are not
restricted under current federal regula-
tions. Before undertaking a reclama-
tion project, however, state and local
authorities should be consulted regard-
ing any special requirements. Although
some states have enacted general provi-
sions concerning the beneficial use of
recovered materials, as of 1996, only
New York State had established specific
landfill reclamation rules. In most
states, officials offer assistance in pro-
ject development, and they review
•work plans on a case-by-case basis. A
few states, such as New York and New
Jersey, encourage landfill reclamation
by making grant money available.
Establish a Preliminary
Worker Health and
Safety Plan
After project planners establish a gener-
al framework for the landfill reclama-
tion effort, they must account for the
health and safety risks the project will
pose for facility workers. Once poten-
tial risks are identified from the site
characterization study and historical
information about facility operations,
methods to mitigate or eliminate them
should be developed. This information
then becomes part of a comprehensive
health and safety program. Before the
reclamation operation begins, all work-
ers who will be involved in the project
need to be well versed in the safety
plan and receive training in emergency
response procedures.
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le program should also cover the
protective equipment workers will be
requked to wear, especially if hazardous
wastes may be unearthed. The three cat-
egories of safety equipment used in land-
fill reclamation projects are:
• Standard safety equipment (e.g.,
hard hats, steel-toed shoes, safety
glasses and/or face shields, protective
gloves, and hearing protection).
• Specialized safety equipment (e.g.,
chemically protective overalls, respira-
tory protection, and self-contained
breathing apparatus).
• Monitoring equipment (e.g., a com-
bustible gas meter, a hydrogen sul-
fide chemical reagent diffusion tube
indicator, and an oxygen analyzer).
Assess Project Costs
Planners can use information collected
from the preceding steps to analyze the
estimated capital and operational costs
of a landfill reclamation operation.
Along with the expenses incurred in
project planning, project costs may also
include the following:
• Capital costs:
— Site preparation.
— Rental or purchase of reclamation
equipment.
— Rental or purchase of personnel
safety equipment.
— Construction or expansion of
materials handling facilities.
— Rental or purchase of hauling
equipment.
• Operational costs:
— Labor (e.g., equipment operation
and materials handling).
Equipment fuel and maintenance.
— Landfilling nonreclaimed waste
or noncombustible fly and bot-
tom ash if waste material is sent
off site for final disposal.
— Administrative and regulatory
compliance expenses (e.g.,
recordkeeping).
—Worker training in safety proce-
dures.
— Hauling costs.
Part of the cost analysis involves
determining whether the various
aspects of the reclamation effort will
result in reasonable costs relative to the
anticipated economic benefits. If the
combustible portion of the reclaimed
waste will be sent to an offsite MWC,
for example, planners should assess
whether transportation costs will be
offset by the energy recovery benefits.
Planners also need to consider whether
capital costs can be minimized by rent-
ing or borrowing heavy equipment,
such as excavating and trommel
machinery, from other departments of
municipal or county governments.
Long-term reclamation projects may
benefit from equipment purchases.
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• f I',' -
Case Studies
Table 1. Landfill Reclamation Project Summaries
Project
Naples Landfill
(Collier County,
Florida)
Edinburg Landfill
(Edinburg,
New York)
Frey Farm Landfill
(Lancaster County,
Pennsylvania)
Operation Start
April 1986
(ongoing).
Dec. 1990 and June
1991 (both completed).
Aug. - Sept. 1992
(completed).
Jan. 1991 -July 1996
(completed).
Mined Area
10 acres
1 acre
1.6 acre
300,000 to
400,000
cubic yards
Use of
Recovered Material
Cover material.
Construction fill.
Waste-to-energy fuel.
Cover material.
Main Objectives
Decrease liability.
Recover soil.
Alternative to
landfill closure.
Reduce landfill
footprint.
Recover fuel.
Reuse of landfill
capacity.
Naples Landfill
Collier County, Florida
In 1986, the Collier County Solid
Waste Management Department
at the Naples Landfill conducted
one of the earliest landfill recla-
mation projects in the country. At
that time, the Naples facility, a
33-acre unlined landfill, con-
tained MSW buried for up to 15
years.
In an evaluation performed by
the University of Florida on 38
of the state's unlined landfills,
investigators discovered that the
Naples Landfill (along with 27
others) posed a threat to ground
water. Moreover, the high cost of
complying with the state's cap-
ping regulations for unlined
landfills concerned many county
officials. Florida's capping regula-
tions required the installation of
a relatively impermeable cover or
cap and postclosure monitoring.
Naples officials developed a recla-
mation plan with the following
objectives: decreasing site closure
costs, reducing the risk of ground-
water contamination, recovering and
burning combustible waste in a pro-
posed waste-to-energy facility, recov-
ering soil for use as landfill coyer
material, and recovering recyclable
materials. Collier County never
built the waste-to-energy plant. The
project did prove successful, howev-
er, in recovering landfill cover mater-
ial. The project proved less successful
at recycling recovered materials (e.g.,
ferrous metals, plastics, and alu-
minum) . These materials required
substantial processing to upgrade
their quality for sale, something the
county chose not to pursue.
In 1991, the U.S. Environmental
Protection Agency selected the
Naples Landfill reclamation project
as a demonstration project for die
Municipal Solid Waste Innovative
Technology Evaluation (MITE) pro-
gram. The MITE program assessed
the excavation and mechanical pro-
cessing techniques used in the piro-
Sourcc Based on: Dickinson, 1995.
ject for reclaiming cover material to
be used in ongoing landfill opera-
tions. It also assessed the capacity
and performance of equipment, the
environmental aspects of the project,
the characteristics of recovered mate-
rials, the market acceptability of
recovered materials, and the proba-
ble costs and economics of the over-
all project. The MITE assessment
found the processing techniques
used in the Naples project effective
and efficient for recovering soil but
not for recovering recyclables of
marketable quality.
During the MITE demonstra-
tion project, Collier County effec-
tively and efficiently recovered a
soil fraction deemed environmen-
tally safe under Florida's MSW
compost regulations. The 50,000
tons of reclaimed soil were suitable
for use as a landfill cover material
and as a soil medium for support-
ing plant growth.
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liiii
ilii
Air quality monitoring indicated
that landfill gas was not an issue at the
reclamation site, apparently due to the
high degree of waste decomposition
that had already occurred. As a result
of this finding, typical personnel pro-
tective gear worn during the project
consisted of standard construction
apparel.
Ongoing reclamation activities at
the Naples facility focus exclusively
on recovering soil for use as landfill
cover material. All excavated materials
other than the reclaimed soil and
small amounts of recyclables are
redisposed of in lined landfill cells.
Reclamation activities are only per-
formed on an as-needed basis. A 3-
inch trommel screen is used to
reclaim the soil cover material. The
weight ratio of reclaimed soil to overs
(i.e., materials caught by the screen),
after white goods and tires are sepa-
rated, is 60 to 40. This indicates that
die Collier County landfill reclama-
tion project is efficient given that 60
percent of the reclaimed material is
reused as landfill cover material.
Based on 1995 prices, landfill cover
material costs Collier County $3.25
per ton. According to Collier County's
director of solid waste, the reclamation
of cover material on an as-needed basis
costs the county $2.25 per ton, a sav-
ings of Si per ton.
According to county officials, the
reclamation project yielded the fol-
lowing benefits: lower operating costs
through reuse of cover materials,
extended landfill life, reduced poten-
tial for ground-water contamination
from unlined cells, and possible
avoidance of future remediation
costs.
Edinburg Landfill
Edinburg, New York
The New York State Energy Research
and Development Authority
(NYSERDA) and the New York State
Department of Environmental
Conservation sponsored projects to
assess the feasibility and cost-effective-
ness of undertaking landfill reclamation
efforts to avoid closures and reduce the
footprint of state landfills. NYSERDA
established these projects in anticipa-
tion of the closure of numerous land-
fills in New York State, and based, in
part, on the success of the Naples
Landfill reclamation project.
NYSERDA's first demonstration
project was conducted at a 5-acre
MSW landfill in Edinburg, New York,
which received waste from 1969 to
1991. NYSERDA chose the Edinburg
Landfill because of its small size and
lack of buried industrial waste. After
NYSERDA chose to sponsor the recla-
mation of 1 acre of the 5-acre landfill,
Edinburg town officials expanded the
project to reclaim 1.6 additional acres.
NYSERDA divided the Edinburg
demonstration project into three phases.
The first phase, started in December
1990, included the excavation of 5,000
cubic yards of waste from a 12-year-old
section of the landfill at an average depth
of 20 feet. The second phase, initiated in
June 1991, included the excavation of
10,000 cubic yards of waste from a 20-
year-old section of the landfill at an aver-
age depth of 8 feet. The first two phases
of the demonstration project cost an
estimated $5 per cubic yard for excava-
tion and processing. This cost included
die inspection and supervision of a fully
contracted operation and was based on
an average excavation rate of 1,000 to
1,200 cubic yards per day.
The third phase of the Edinburg
project occurred from August to
September 1992. NYSERDA provided
the majority of the project funding,
with the remaining funding (primarily
for phase three) provided by the town
of Edinburg. This third and final
phase reclaimed an additional 1.6 acres
(31,000 cubic yards) in 28 days.
Because the town supplied required
equipment and labor, the contracted
cost for this phase decreased from $5
per cubic yard excavated to $3 per
cubic yard. Subsequently, the town
looked into reclaiming the remaining
2.4 acres of the landfill and completely
eliminating the footprint. The pro-
posed fourth stage proved unviable, so
the remaining portion of the landfill
will be capped.
The Edinburg Landfill is located in
a soil-rich area that provides ample
amounts of landfill cover material. For
this reason, officials tested and
approved the reclaimed soil (75 per-
cent of the reclaimed material) for off-
site use as construction fill in
nonsurface applications. A test burn
performed on the reclaimed waste
found the British thermal unit (Btu)
value to be lower than desired because
of the high degree of waste decompo-
sition and stones remaining in the
screened material.
The recovered nonsoil materials,
representing 25 percent of the
reclaimed waste, were hand-sorted
for potential recyclables. Although
50 percent of the nonsoil material
was considered recyclable, cleaning
the materials to market standards was
not feasible. Some tires, white goods,
and ferrous metals, however, were
separated and recycled. The remain-
ing materials were sent to a nearby
landfill.
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NYSERDA officials developed a
worker health and safety plan for the
Edinburg project that established work
zones, personnel protection require-
ments, and other operating procedures.
The inspectors, as well as all personnel
working at the site, were required to
wear respirators, goggles, helmets, and
protective suits. Excavation equipment
was used to separate suspicious drums
and other potentially hazardous material
for evaluation by the safety inspector
using appropriate monitoring equip-
ment. In the event that hazardous mate-
rials were encountered, the health and
safety plan provided for a project con-
tingency plan, a segregated disposal area,
and special waste handling procedures.
No significant quantities of hazardous
materials, however, were unearthed.
The Edinburg Landfill Reclamation
Project was successful both in securing
offsite uses for the reclaimed soil and
in reducing the landfill footprint to
decrease closure costs. The economic
benefits would be enhanced further if
the avoided costs for postclosure main-
tenance and monitoring, as well as
potential remediation and the value of
recovered landfill space, are also
considered.
Frey Farm Landfill
Lancaster County,
Pennsylvania
In 1990, the Lancaster County Solid ,
Waste Management Authority con-
structed an MWC to use in reducing
the volume of waste deposited in the
Prey Farm Landfill, a lined site (double
layers of 60-mil high density polyethyl-
ene sheeting on a 6-inch clay sub-base)
containing MSW deposited for up to 5
years. After building the MWC, the
quantity of waste received at the facility
declined, leaving a significant portion
of the MWC capacity unused. In an
effort to increase the energy production
and efficiency of the MWC, officials
initiated a landfill reclamation project
to augment the facility's supply of fresh
waste with reclaimed waste.
The reclaimed waste had a high Btu
value (about 3,080 Btu per pound). To
achieve a more efficient, higher heat-
ing value of 5,060 Btu per pound of
waste, four parts of fresh waste, which
included tires and woodchips, were
mixed with one part reclaimed waste.
Between 1991 and 1993, approxi-
mately 287,000 cubic yards of MSW
were excavated from the landfill. These
reclamation activities processed 2,645
tons of screened refuse per week for
the MWC. As a result, Lancaster
County converted 56 percent of the
reclaimed waste into fuel. The county
also recovered 41 percent of the
reclaimed material as soil during trom-
meling operations. The remaining 3
percent proved noncombustible and
was reburied in the landfill. By the
end of the project in 1996, landfill
operators had reclaimed 300,000 to
400,000 cubic yards of material.
Before the reclamation work began,
officials prepared a safety plan for
work at the site and assigned a full- :
time compliance officer to oversee the
operations. During reclamation, work-
ers took precautions to avoid damag-
ing the site's synthetic liner, since it
would be reused following the recla-
mation operations. An initial layer of
protective material surrounded the
synthetic liner system, aiding worker
precautions by acting as a buffer ;
between the liner arid the excavation
tools. Continuous air monitoring for
methane, both in the cabs of vehicles
and in the reclamation area, enhanced
the operation's safety operations.
Benefits of the project at Frey Farm
Landfill include: reclaimed landfill
space, supplemented energy produc-
tion, and recovered soil and ferrous
metals. Drawbacks include: increased
generation of ash caused by the high
soil content found in reclaimed waste,
increased odor and air emissions,
increased traffic on roads between the
MWC and the landfill, and increased
wear on both the landfill operation
and MWC equipment (i.e., due to the
abrasive properties of the reclaimed
waste).
Costs for the resource recovery por-
tion of the project were relatively low
for the following reasons:
• The distance for transporting both
the reclaimed waste and the ash was
only 18 miles each way.
• The management authority avoided
commercial hauling prices by using
its own trucks and employees to
transport the reclaimed waste and
the ash.
• The landfill and MWC were operat-
ed by the same management authori-
ty, thus no tipping fees were required.
: (Generally, a higher tipping fee can
be charged at an MWC for reclaimed
waste because of its abrasiveness and
higher density, which increases the
wear and tear on equipment.)
By 1996, MWC facility operators
no longer needed supplemental feed
materials from Frey Farm Landfill to
run at full capacity. Thus, landfill offi-
cials concluded the reclamation project
in July of that year.
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References
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Ma«h/April:4(j.
Fcmtcr, G. 1994. Assessment of Landfill Mining and the Effects of Age on
Combustion of Recovered Municipal Solid Waste. Landfill Reclamation
Conference, Lancaster, PA.
Morclli, J. 1992. Town of Edinburg Landfill Reclamation Demonstration Project.
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Information
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Management, March/April:54-<33.
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Reclamation Conference, Lancaster, PA.
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mental problem. The Wcstchcstcr Engineer, April:56(8).
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Combustion of Recovered Municipal Solid Waste. Golden, CO, National
Renewable Energy Laboratory. January.
Gagliardo, P.E, and XL. Stccle. 1991. Taking steps to extend the life of San Diego's
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June.
Kelly, WR. 1990. Buried treasure. Civil Engineering, April:52-54.
LCSWMA. 1992. Landfill Reclamation. Lancaster County Solid Waste
Management Authority, Lancaster, PA. April.
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118-120.
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September:121-124.
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75-78.
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Reclamation Conference, Lancaster, PA.
NYSERDA. 1990. Town of Edinburg Landfill Reclamation Fact Sheet. New York
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Rettenberger, G., S. Urban-Kiss, R. Schneider, and R. Goschl. 1995. German pro-
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RRR. 1993. Three mining projects begun. Resource Recovery Report, December:6.
Spencer, R, 1990. Landfill space reuse. BioCycle, February:30-32.
Spencer, R. 1991. Mining landfills for recyclables. BioCycle, February:34.
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R-96-149. Washington, DC. June.
United States
Environmental Protection Agency
(5306W)
Washington, DC 20460
Olficial Business
Penally for Private Use
$300
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Executive Summary
Historical Goals
The Superfund program is one of
the nation's most ambitious and
complex environmental programs.
Launched in 1980, with the passage
of the Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA),
Superfund's primary goal is to protect
human health and the environment.
This goal is achieved in several ways.
• First, CERCLA provides
unparalleled enforcement
powers based on the belief that
polluters should take responsi-
bility for cleaning up their own
wastes.
• Second, CERCLA's authority
for Federal response enables
EPA to protect human health
and the environment in the event
responsible parties do not take
timely, adequate action.
• Finally, CERCLA establishes a
Hazardous Substances Response
Trust Fund to cover the costs of
enforcement and cleanup
activities.
The Challenge
At the outset of the Superfund
program, EPA's primary challenge
was to respond to cleanup requests
while building an organizational
structure and staff, developing
program policies and guidance, and
accumulating money in the Trust
Fund to support program operations.
Today, EPA has a solid infrastructure
in place to manage
this complex program.
In ongoing efforts to
enhance its manage-
ment systems and
engineering capabili-
ties, EPA is exploring
new frontiers in science and technol-
ogy. Total Quality Management
(TQM) approaches, which are
revolutionizing the business world,
are being implemented and EPA is
sharing with the public tangible
environmental improvements.
In 1989, the Administrator of
EPA completed a Management
Review of the Superfund Program
(commonly known as the 90-Day
Study). This review provides a
candid self-evaluation of past pro-
gram activities and achievements,
identifies conflicting mandates and
needs for program enhancements, and
makes a commitment to following a
practical plan for the future. This
plan is based on a set of eight strate-
gic goals:
• Control acute threats immedi-
ately. EPA will get into the
field fast, size up the scope of
the problem, and undertake
appropriate action right away to
ensure protection from immedi-
ate threats to people and the
environment.
• Emphasize enforcement. EPA
will encourage or compel
responsible parties to conduct
more site work to increase the
total number of cleanups.
• Address worst sites/worst
problems first. After attacking
the immediate threat, the
Agency will begin the earliest
remedial work to address
... the Agency has a clear plan for
the second decade of Superfund and
beyond...
problems that remain high
priority when compared to
competing problems at other
sites.
Monitor and maintain sites
over the long-term. EPA will
monitor Superfund sites over
the long-term to ensure that the
remedy remains protective of
human health and the environ-
ment.
vil
-------
Executive Summary
Develop and use new technolo-
gies. EPA will develop, demon-
strate, and use permanent
technologies to achieve final site
cleanups, to the maximum
extent practical.
Improve efficiency of program
operations. EPA will improve
the efficiency of program
operations by pursuing a "one
Superfund" approach to site
cleanup activity and enforce-
ment against polluters.
Encourage full public partici-
pation. EPA will increase the
role of citizens in Superfund
decisions and encourage clear
and consistent two-way commu-
nication with the public.
... resources are directed toward the
worst problems first to minimize risk
and maximize protection
• Foster cooperation with other
Federal and State agencies.
EPA will work with State
agencies, natural resource
trustees, Indian Tribal Govern-
ments, and other Federal agen-
cies to ensure an effective and
cooperative relationship.
EPA developed these eight goals
based on the lessons learned during
the first 10 years of the program, and
will build upon those lessons to chart
the course for the future.
The Turning Point:
A New Strategy
From these goals, a strategy for
the next decade of Superfund has
emerged. Simply stated, that strategy
is to:
• Enforce aggressively
• Make sites safe
• Make sites clean
• Bring new technology to bear
in solving hazardous waste
problems.
The Superfund program's theme of
solving the worst problems at the
worst sites first is right in step with
the Agency's
overall policy for
prioritized risk
reduction. Under
this policy, re-
sources are directed
, •• -- ^ toward the worst
problems first to
minimize risk and maximize protec-
tion of human health and the environ-
ment.
Today, a decade after CERCLA's
enactment, the guiding principles of
the original Superfund program
remain intact. In fact, the Superfund
Amendments and Reauthorization
Act of 1986 (SARA) adopted the
majority of policies and procedures
the Agency had developed during the
first 5 years of the program, and
provided a number of changes to
strengthen and fine tune the program.
In November of 1990, Congress
passed a 3-year extension of the
taxing authority for Superfund,
ensuring uninterrupted implementa-
tion of the program through 1994.
The Future Is
Built On The Past
EPA recognizes that the hazard-
ous waste problem in the United
States remains large, complex, and
long-term. There are no easy solu-
tions, but the Agency has a clear plan
for the second decade of Superfund
and beyond. EPA is conducting
studies that will help define the total
universe of Superfund sites, how
much it will cost to clean up those
sites, and the future role of enforce-
ment and States in reaching the
ultimate goal of protecting human
health, welfare, and the environment.
This 10-year perspective report is
designed to provide an overview of
Superfund program activities, to
illustrate the clear progress that has
been made in addressing uncontrolled
hazardous waste sites nationwide, and
to point the direction for the future of
the program.
Vlll
-------
Legislative And Regulatory Framework
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Rules And Tools
Superfund was created by
Congress in 1980 with the passage of
the Comprehensive Environmental
Response, Compensation, and
Liability Act of 1980 (CERCLA).
CERCLA arose out of the need to
protect citizens from the dangers
posed by abandoned or uncontrolled
hazardous waste sites. Most Ameri-
cans can remember nightly news
broadcasts in the late 1970s describ-
ing the thousands of leaking drums
and ground water threats discovered
at the Love Canal site in Niagara
Falls, New York. CERCLA gave the
Federal government broad authority
to respond to hazardous substance
emergencies, and to develop long-
term solutions for the nation's most
serious hazardous waste problems
like Love Canal.
The term "Superfund" referred to
a $1.6 billion Hazardous Substance
Response Trust Fund established to
pay for cleanup and enforcement
activities at waste sites. This fund
was financed primarily with a tax on
crude oil and 42 commercially used
chemicals. The tax supported the
concept that those responsible for
environmental pollution should
assume the cost. The original law
also enabled the Federal government
to recover the costs of its actions
from those responsible for the
problem, or to force them to clean up
the hazardous site at their own
expense.
On October 17, 1986, the
Superfund Amendments and Reau-
thorization Act of 1986 (SARA) was
enacted. SARA reflected EPA's
experience in administering the
complex Superfund program during
its first 6 years. The reauthorized
law made several important changes
and additions to the program:
• Increased the size of the Trust
Fund from $1.6 billion to $8.5
billion
• Stressed the importance of
permanent remedies and
innovative treatment technolo-
gies in cleaning up hazardous
waste sites
... those responsible for
environmental pollution
should assume the cost.
Established specific cleanup
goals and schedules
Required Superfund actions to
consider the standards and
requirements found in other
Federal and State environ-
mental laws and regulations
Expanded the statutory cost
and duration limits on removal
actions
Provided new enforcement
authorities and settlement tools
Increased State involvement
in every phase of the Super-
fund program
Increased the focus on human
health problems posed by
hazardous waste sites
Encouraged greater citizen
participation in making
decisions on how sites should
be cleaned up
-------
Legislative And Regulatory Framework
• Expanded research and train-
ing activities to promote the
development of alternative
and innovative treatment
technologies
• Required cleanup of Federal
facilities to meet Superfund
requirements.
In response to the tragic toxic
chemical release in Bhopal, India,
and a subsequent serious incident in
Institute, West Virginia, Congress
also established new reporting
requirements for facilities that
handle hazardous chemicals.
Title III of SARA, the Emergency
Preparedness and Community
Right-to-Know Act of 1986,
established a four-part program to
define an emergency planning
structure at the State and local
levels; require emergency notifica-
tion of hazardous chemical releases;
require notification of chemical use,
storage, or production activities;
and define annual emissions report-
ing requirements.
The Superfund response effort
is guided by the National Oil and
Hazardous Substances Pollution
Contingency Plan, commonly
referred to as the National Contin-
gency Plan (NCP). This plan
outlines the steps that EPA, the U.S.
Coast Guard, and other Federal
agencies must follow in responding
to situations in which hazardous
substances or oil are released into
the environment. Fourteen Federal
agencies are members of the
National Response Team (NRT),
which is responsible for planning
and coordinating preparedness and
response actions.
The NCP, which actually
predates Superfund, was originally
written to implement provisions in
the Clean Water Act having to do
with spills of oil and hazardous
substances into navigable waters. It
has been revised three times: first to
incorporate the 1980 Superfund
program, then later in 1985 to
streamline the Superfund process,
and most recently in March 1990 to
address significant changes in the
Superfund program resulting from
the enactment of SARA. The NCP
is currently being revised to include
the new requirements of the Oil
Pollution Act of 1990.
The national goal described in
the NCP is to select remedies that
are protective of human health and
the environment, that maintain
protection over time, and that
minimize untreated waste. The
Superfund program expects to
achieve this goal in several ways:
• Use treatment technology on
principal threats, wherever
practical
• Consider isolation and contain-
ment for wastes posing mini-
mal threats or where treatment
is impractical
• Combine treatment with
containment, as necessary
• Supplement engineering
solutions with institutional
controls such as deed restric-
tions wherever appropriate
• Consider innovative treatment
technologies
• Return ground waters to their
beneficial uses as soon as
possible.
The Superfund Process
The process established by the
NCP for meeting these expectations
and handling hazardous waste
problems begins with learning where
a hazardous waste site might exist
(see Superfund Process Flowchart,
Figure 1). If, based on a preliminary
*= Two Types Of Response: Removal And Remedial Actions
••'-. • • -- / ,>'„'
Every Superfund site is unique, and cleanups must be tailored to the specific needs'
of each site or release of hazardous substances. From the beginning of the process,
EPA makes a concerted effort to encojirage those' responsible to pay for cleanup.
However, if an immediate problem threatens human health, welfare, or the environ-
ment, EPA will take action. EPA can respond to hazardous substance releases in
two ways as defined by CERCLA: , „
• Removal Actions—short-term actions which stabilize or clean up a hazardous
site that poses a threat to human health or the'environment. Typical removal
actions include removing tanks or drums of hazardous substances from the
surface, excavating contaminated soil, installing security measures at a site, or
providing a temporary alternate source of drinking'water to local residents./ „
•- „-'„:,'' •"• - - ~ , * / , - TI t
• Remedial Actions—the study, design, and'construction of longer-term and
usually more expensive actions aimed at permanent remedy. EPA can take ',
remedial actions only at sites on the National Priorities List (NPL)—EPA's list •
of the nation's most serious hazardous waste sites.' Typical remedial actions'
include removing buried drums from'a site, constructing underground walls to',
control the movement of ground water, incinerating wastes, or applying/,
bioremediation techniques or other innovative technologies to^contaminated >
• soil. ~* -
-------
Legislative And Regulatory Framework
evaluation there is an emergency
requiring immediate action, the next
step is to act as quickly as possible
to remove or stabilize the threat.
These actions are known as remov-
als (see box on previous page).
Even after the necessary emer-
gency action has been taken to
control the immediate threat, in
some cases contamination may
remain at the site. A more detailed
analysis of the contamination may
be necessary to determine if further
work needs to be done to find a
permanent solution at the site. If
long-term action is necessary, a
decision must be made regarding the
relative national priority of that
particular site. These long-term
actions are known as remedial
actions (see box on previous page).
An investigation of the extent of
contamination and analysis of the
range of alternative remedial actions
Superfund might take is then con-
ducted. Concerns of the State and
local community are seriously
considered in determining which
alternative to select. Efforts also are
Figure 1
Superfund Process Flowchart
Continuous
Enforcement
Efforts
Site Discovery
Preliminary Assessment (PA)/
Site Inspection (SI)
Hazard Ranking System (MRS)/
National Priorities List (NPL)
Remedial Investigation (Rl)/
Feasibility Study (FS)
Continuous
Participation
Selection of Remedy
Removal Action
At Any Point,
As Necessary
Operation and Maintenance (O&M)
NPL Deletion
made to find individuals or compa-
nies responsible for the contamina-
tion and make them pay for and/or
conduct the cleanup.
After the remedial action has
been selected, it must be designed
and constructed. Once action has
been completed, the site often must
be monitored and maintained, a
responsibility which is assumed by
the State or responsible party.
Typically, a Superfund cleanup
action follows this sequence of
events, but not always. For ex-
ample, an emergency requiring
immediate attention can occur at a
site which already is undergoing a
long-term remedial action.
At all stages of response, work
can be done by a State or EPA using
the Trust Fund, or by responsible
parties as a result of enforcement
efforts. In addition, community
relations activities and enforcement
actions take place throughout the
cleanup process to ensure optimal
use of Trust Fund resources and the
involvement of all interested parties
in the decisionmaking process.
The following sections of this
report examine in detail each step of
the decisionmaking process for
Superfund removal and remedial
responses, highlight the major
accomplishments in each program
area, and provide an overview of
new Superfund program initiatives.
-------
Removal Actions
Fires, explosions, contaminated
drinking water, and toxic fumes.
These are just some of the situations
the removal program regularly
confronts. When there is no time for
lengthy analysis of a hazardous
substance release and no one else is
available who has the technical and
financial capability to respond,
Superfund removal program person-
nel are on the scene responding as
quickly as possible to reduce imme-
diate threats to human lives and the
environment.
The removal program has been
the most rapidly productive compo-
nent of the Superfund program, with
more than 2,300 cleanups started
and 1,900 cleanups completed since
1980 (see Figure 2). Virtually every
day in 1990, a removal action was
started somewhere in the U.S. and
its territories. That rate has been
remarkably consistent since 1987
when the Superfund Amendments
and Reauthorization Act (SARA)
doubled its limits on time and cost
for removals to 12 months and $2
million. While remedial actions are
usually more expensive, extensive,
and often receive more media
coverage, the removal program has
been a key contributor to the overall
success of the Superfund program in
responding to hazardous substance
threats across the country.
Removal actions are taken at
all types of sites including inactive
waste facilities such as open dumps
or landfills that have been closed
— the most rapidly
productive component
of the Superfund
program.
- . ...., , • , , . * *-
|A removal action provides a rapid and flexible response to reported health andr
-environmental hazards, wherever and whenever they occur. Removals are;^
r - : : :-':,": »"*'"!:.L.: - =-"• -^ - , ^ , ^ ' < '"° } ''*}
i • Investigated and assessed within hours of being feported,'24 hours a day,' * *
' 365 days a year
i. _ , •- , * , . < ^ < . t " f ^ '*
\ s Conducted at both National Priorities List (NPL) and non-NPL sites
l>
• Conducted by Oil-Scene Coordinators (OSCs) from EPA or the U.S,
Coast Guard (USCG) ' '''"''„
* »* ^~ ^ * / &*<. »@p * ? / '„ > * / s * ' t^>; '**" ' ^
• Kept consistent with any potential long-term remedial actions
„"„'""' , "t ' ' ' '"' ' ^ * " I
• Limited, unless specially exempted"! to 12 month? for completion and'$2
| i 11 million in costs.
L
Figure 2
Removal Action Starts and Completions*
Z4UU "
2200 "
2000
1 18°°
o 1600
g 1400
"o
§
13 800
600
400
200
n -
^^^mgl
— Removal Action Starts
«— Removal Action Completi
•
^*<
1^"'"
^^s
A
^
3PS
/
/
f
J
/
' /
/
/
/ ,
y
^
/
Fiscal Year
* Totals are for combined EPA, U.S. Coast Guard, and Potentially Responsible Party-lead removal actions
down or abandoned; "midnight
dumps" where drums or other con-
tainers have been illegally disposed
of in secluded woods, open fields, or
other locations; active manufactur-
ing or waste disposal facilities,
chemical manufacturers, and operat-
ing landfills; and transportation-
related accidents such as toxic
chemical releases from derailed
trains or overturned trucks. Cover-
ing a wide range of situations,
removal actions typically include a
variety of substances and health and
environmental threats. For example,
removal actions address threats to
communities and ecosystems from
fire and explosion; human direct
contact risks due to drinking water
or soil contamination; improper
-------
Removal Actions
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hydrogen cyanide: sampling/ packing, mnd removing -drums;- remote crusnihg OF ,"
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-------
Removal Actions
Figure 3
Overview of Removal Process
Notification
or
Discovery
1
Conduct Removal
Site Evaluation (RSE)
*
Assess RSE results
against removal action
criteria in NCP
Meet Criteria End response or refer
program (if appropriate)
w Meets Criteria
Obtain approval for
removal action
I
T
Initiate site action
*
Oversee cleanup
contractors
*
Action completed
1 1 Public Participation
Ongoing Enforcement
responsible parties (PRPs), whose
cleanup activity is monitored by
EPAorUSCG. In light of
Superfund's increased emphasis on
enforcement, it is significant that the
number of PRP-managed removal
actions has steadily increased,
accounting for 98 of the 351 starts in
1990.
Organization And Proce-
dures For Rapid Response
The National Response Center
(NRC), operated by the USCG in
Washington, D.C., is the official
clearinghouse for all reports of oil
and hazardous substance releases.
The Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA) requires
that any manufacturer, waste facility
operator, or common carrier imme-
diately report releases of hazardous
substances (above substance-specific
thresholds known as "reportable
quantities") to the NRC.
When the release or potential
release is from an inactive waste
facility or from an illegal dump,
however, reporting is less routine.
The amount of the release—and
even the substance being released—
may not be known immediately, and
the NRC may receive only partial
information from State or local
public safety officials or the general
public.
Whether information is com-
plete or partial, the NRC alerts the
appropriate EPA or USCG Regional
OSC as well as State officials and
other Federal agencies with a
potential interest. The NRC also
alerts the EPA Emergency Response
Division in Washington, D.C.,
which sets policy for and manages
the removal program; but the NRC's
primary responsibility is the imme-
diate notification of the designated
Regional OSC. OSCs are on call 24
hours a day to respond to reports of
releases that may require a Super-
fund removal action.
The first task of the OSC may be
to assist public safety officials in
their efforts to protect the public.
This may include emergency efforts
to secure the site, ensure fire control,
provide emergency alternate water
supplies, or assist in temporary
evacuation.
-------
Removal Actions
After public safety has been
secured, the OSC begins a removal
site evaluation. The objective is to
determine the potential for or source
of the release, the threat to human
health, whether another party is
conducting a proper response, and
the appropriate course of action.
Regional and National Response
Teams are available to provide
technical assistance to the OSC
during this evaluation. With this
assistance, the OSC is responsible
for documenting the situation and
determining whether a short-term,
relatively low-cost response—a
removal action—is sufficient to
stabilize or clean up the site.
If the OSC determines that the
situation does not require a removal
action, the site may be referred to
the Hazardous Site Evaluation
Division of EPA to be evaluated for
inclusion on the NPL and possible
remedial action, or it may be re-
ferred to another interested Federal
or State agency for action.
While the site is being evalu-
ated, the OSC also must determine
whether one or more PRPs are
capable and willing to assume
responsibility, under EPA supervi-
sion, for the appropriate course of
action. If the PRPs are unknown,
unwilling, or incapable of assuming
timely responsibility, the OSC
initiates a CERCLA-funded removal
action. Identified PRPs are not
released from responsibility, how-
ever. Throughout the course of the
removal action, the OSC or enforce-
ment personnel continue efforts for
PRP involvement and cost recovery.
Throughout the planning and
execution of a removal action,
opportunity for public participation
is mandated by CERCLA. Informa-
tion must be provided and public
response solicited. Only the require-
ments of public safety are allowed to
override this policy. Figure 3, on
the previous page, presents an
overview of the removal process.
New Directions For The
Removal Program
The most sweeping changes to
the removal program have occurred
as a result of expanded statutory and
regulatory authorities. Among the
most significant changes imple-
mented as a result of SARA, and
reflected in subsequent revisions to
the National Oil and Hazardous
Substances Pollution Contingency
Plan (NCP), are:
• Expanded response author-
ity: The limitations on removal
actions were increased from 6
to 12 months, and from $1
million to $2 million, to reflect
actual time and cost constraints
encountered during the first 6
years of the program. These
expanded limits increase the
flexibility of the removal
program to respond to various
threats and help achieve greater
coordination with the remedial
program.
• Contribution to remedial
performance: Removal
actions must be designed to
contribute to the efficient
performance of any subsequent
long-term remedial action.
-------
Removal Actions
I Expanded Authority And State-Of-The-Art Technology
\ ~ . :. . •. : •"•:: -_,•-
^Southeastern Wood Preserving in downtown Canton, Mississippi operated from
iU928 until early 1979, when its owners filed for bankruptcy and abandoned the
•site. EPA initiated an emergency removal action in June 1986 to stabilize three
!t over-flowing surface impoundments containing creosote sludge and
Thirty-thousand gallons of water were pumped from the flooded areas of
|the site. EPA proposed that the second phase of cleanup consist of either on-site
pfeatment or off-site disposal of the stabilized sludge.
X - ..
mln December 1988, the Department of Agriculture's Soil Conservation Service
i(SCS) contacted EPA. \Vhile surveying a creek that borders the site, SCS had
inotiecd oily waste leaching into the creek. Through an Interagency Agreement,
^SCS worked with EPA to excavate the contaminated soils.
Un August 1989, EPA approved an exemption from the 12-month statutory limit on
l removal actions. The Region approved additional funds to continue excavations
H»nd to conduct on-site treatment of the contaminated sludges. The sludges
^threaten to contaminate soil and drinking water (a municipal well is within 100
rfeet of the site) and continue leaching into the creek (children playing in a park a '
;mile downstream from the site have complained of creosote burns). EPA is
'proposing to use biological remediation to treat the 8,000 cubic yards of contami-
nated soil left on the site. In August 1990, the EPA Region obtained an exemption
from the $2 million statutory limit to cover additional costs to meet stringent land
^disposal and air emission standards. Bioremediation is scheduled to begin in 1991.
Use of alternative technolo-
gies: When possible, EPA
considers cost-effective re-
moval action alternatives that
use recycling or treatment of
waste rather than land disposal.
This requirement promotes the
use of cleanup technologies that
reduce the toxicity, mobility, or
volume of waste.
• Compliance with applicable
or relevant and appropriate
requirements (ARARs): On-
site removal activities are
expected to identify and
comply with all Federal (be-
yond CERCLA) and State
environmental and human
health laws to the extent
possible given the circum-
stances of the removal. This
ensures that removal actions are
conducted in a way that best
prevents damage to human
health, welfare, and the envi-
ronment.
• Off-site disposal: If a removal
action requires off-site disposal
of hazardous wastes, those
wastes must be sent to environ-
mentally-sound (RCRA-
approved) facilities. This helps
to ensure that wastes from
removal actions will not create
future Superfund sites.
These changes in authority and
program emphasis have increased
the removal program's flexibility to
respond to hazardous substance
releases while also promoting
environmentally sound technologies
and practices that reduce threats to
human health and welfare. The
removal program continues to
evolve in its flexibility and respon-
siveness as the Agency endeavors to
control immediate threats to people
and the environment.
Recently, the Superfund Man-
agement Review set forth a compre-
hensive, long-term strategy for the
Superfund program. Three elements
of the eight-part strategy have
especially important implications for
the removal program:
-------
• Control acute threats immedi-
ately
• Address the worst sites and
worst problems first
• Emphasize enforcement to
induce private party cleanup.
Progress towards these goals had
already begun within the removal
program prior to the Superfund
Management Review. For example,
the Regions expanded an evaluation
effort already underway concerning
the need to control acute threats
immediately at existing NPL sites.
EPA also established timeframes for
conducting assessments at newly
proposed NPL sites and for follow-
up. Additionally, EPA is focusing
on methods to accelerate response at
NPL sites that use removal and
remedial program coordination to
make sites safer and address the
worst sites first. While the majority
of threats at NPL sites are addressed
through the remedial program,
certain sites may benefit from the
flexibility and streamlined response
options offered by the removal
program. Finally, EPA is emphasiz-
ing a strong "enforcement first"
approach for the Superfund program
in order to promote more private
party cleanups through the use of
enforcement and settlement authori-
ties.
The strength of the removal
program lies in its ability to mobilize
expertise and resources to respond to
immediate, critical hazardous
substance threats. Remedial actions
often receive more attention, as local
sites are scored and evaluated for
inclusion on the NPL. They also
Figure 4
Enforcement-Lead Removal Actions *
600
2 500
0>
oc
400
0 300
200
100
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
* Figures shown are for enforcement-lead removal action starts at NPL and non-NPL sites.
generally receive more resources, as
long-awaited, full cleanups are
planned and implemented. But the
removal program is fast, flexible,
and operates whenever and wherever
a release or a potential for a release
of hazardous substances poses a
threat to human health, safety, or the
environment.
The increase in cost limits for
removal actions does not mean, of
course, that the removal program has
been exempted from national and
EPA fiscal constraints. Priorities
have been set—addressing immedi-
ate threats at NPL and non-NPL
sites first. Less immediate threats at
NPL sites will be addressed only as
resources permit. Enforcement has
steadily improved, as well. Overall,
there were 98 PRP-led removal
actions in 1990, up from 47 in 1986.
Enforcement is now making it
possible to address a greater number
Of sites each year (see Figure 4).
Over the last 10 years, the
removal program has developed an
organization and procedures in
keeping with its mission. It has been
able to maintain the speed and
flexibility of a decentralized pro-
gram while cultivating crucial health
and safety expertise. The expanded
response authority granted under
SARA is not only an indication of
rising response costs but an ac-
knowledgment of the importance of
the program within Superfund. The
removal action program has been
successful in creating an effective
EPA presence at non-NPL sites and
in stabilizing and mitigating the
worst problems at NPL sites until
the remedial program can implement
complete cleanups.
-------
Site Assessment Activities
The primary goal of the site
assessment program is to identify
the most serious hazardous waste
sites in the nation and list them on
the National Priorities List (NPL), a
catalogue of those sites with a
potential need for remedial action.
Site assessment is the initial phase of
Superfund response, and the process
by which EPA and the States
identify, evaluate, and rank hazard-
ous waste sites. Within this frame-
work, however, specific objectives
for the program have shifted over
the course of Superfund's 10-year
history. In part, this is because the
scope and magnitude of the problem
of neglected hazardous waste sites
was vastly underestimated when the
Superfund program began.
The Superfund program was
originally conceived as a 5-year
effort that would address the 400
worst abandoned hazardous waste
sites in the nation, and gradually be
phased out of existence. Since 1980,
however, it has become clear that
the total number and distribution of
hazardous waste sites far exceeds
any of the original estimates.
Between 1980 and 1986, the
major emphasis for the site assess-
ment program was on establishing
program requirements and develop-
ing the Hazard Ranking System
(HRS), which enables EPA to
evaluate numerically the relative risk
of each site listed in the Comprehen-
sive Environmental Response,
Compensation, and Liability Infor-
mation System (CERCLIS), the
official information system for the
Superfund program. EPA then
established a cut-off point for sites
that would be eligible for Federal
cleanup funds. It was the Agency's
goal at that time to place a minimum
of 400 of the nation's worst sites on
the NPL, based on their HRS scores.
With the 1986 enactment of the
Superfund Amendments and Reau-
thorization Act (SARA), Congress
pSite assessment activities help identify and assess the most serious hazard-*
|ous waste sites in the nation. These activities include the following step's:
1 • Site discovery—identifying hazardous substance releases"through i ' •
• - formal and informal channels ,~ ' ' , ,
p li * * my" *a Hf* jfc I * J , f a f ~ 4
|B • Preliminary assessment (PA)—evaluating existing sjte-specific
, data for early determination of need for further action / r_ -f
|. • Site inspection (SI)—assessing on-site conditions and characteris-
i tics to determine if an HRS score should be developed - ' t
|. • Hazard Ranking System (HRS) score—applying a mathematical^
i ^ approach to assessment of relative risks posed by sites '
t • NPL listing—determining those sites that are eligible for Superfund-' ^
r financed remedial action. , ; ' ' ',-•''/ ''
f * * * ~* ' ' ' - *
developed measurable goals for the
Superfund site assessment program.
Specifically, SARA mandated that
for all sites listed in CERCLIS as of
October 17, 1986, preliminary
assessments (PAs) must be com-
pleted by January 1, 1988, and site
inspections (Sis) must be completed
by January 1,1989. In addition,
SARA required that EPA revise the
HRS to emphasize potential human
health risks and damage to ecosys-
10
terns. These changes demonstrated
that a new emphasis was being
placed on the site assessment
program, not just as a preliminary
phase to the remedial program but as
a rigorous screening program
designed to determine which sites
should continue through the process
to NPL listing. The site assessment
program is critical because once a
site is listed on the NPL it becomes
eligible for Federal cleanup funding.
-------
Site Assessment Activities
Since 1986, 10,700 sites have
had PAs and 6,300 of these sites
have undergone Sis. The NPL,
which began in 1981 as an "Interim
Priorities List" of 115 sites, now
Congress developed measurable
goals for the Superfund site
assessment program.
locating sites that would otherwise
go unnoticed. For example, Region
X has an active site discovery
program that uses geographic
information systems and makes use
of historical indus-
trial business lists
and EPA program
lists to identify
sensitive or vulner-
able areas where
releases would be
significant.
contains nearly 1,200 sites. Based
on past rates of listing, the Agency
expects to list approximately 100
sites per year. The NPL will likely
contain 2,100 sites by the year 2000.
The Site Assessment
Process
Site Discovery
EPA learns of releases that
potentially warrant Superfund
response through both formal and
informal channels. The Comprehen-
sive Environmental Response,
Compensation, and Liability Act
' (CERCLA) notification require-
ments mandate that any person who
knows of a hazardous substance
release notify the Federal govern-
ment. Moreover, under SARA,
owners or operators of facilities that
produce, use, or store extremely
hazardous substances are required to
notify the local emergency planning
committee and State emergency
response commission if at any time a
release exceeds reportable quanti-
ties, as described in the Removal
chapter.
In addition to these mandatory
reporting requirements, EPA has
also relied on public petitions and
informal citizen reports to learn
about existing or potential hazardous
waste sites. From time to time,
Regions have taken an active role in
Preliminary Assessments
The first step the Agency takes
after learning of a potential site or
release is to obtain and review all
available reports and documentation
about the site. As originally con-
ceived, the PA was a desk-top
evaluation of existing site-specific
data designed to determine whether
a site merits further action under
CERCLA.
Recently, however, the scope of
the PA has been expanded to
provide more information and
expedite the decisionmaking pro-
cess. The expanded PA, which
includes site reconnaissance and a
projected numerical rating for the
relative hazards posed, enables EPA
to identify priorities more accurately
and consistently, and allows for
early identification of sites that need
no further action by the Federal
government.
About half of all sites are
eliminated from further CERCLA
consideration at this step, with a
decision of no further remedial
action planned (NFRAP). Sites that
present a clear and immediate
danger to human health and the
environment and, therefore, require
immediate action may be referred to
the Superfund removal program.
Other sites may be referred to other
environmental programs, as appro-
priate. The remaining sites move on
to the SI stage in the site assessment
process. Approximately 5 percent of
those sites receiving an HRS score
go on to be included on the NPL. At
any stage in the site assessment
process, a site may be referred to the
removal program, referred to
another environmental program, or
determined to need no further action.
As of January 1990, 94 percent
of the 33,000 sites currently in
CERCLIS have been assessed,
meaning that more than 31,000 PAs
have been conducted over the course
of Superfund's 10-year history. To
prevent a backlog, and to comply
with the intent of SARA, EPA's
policy is to conduct a PA within 1
year of a site's listing in CERCLIS.
Site Inspections
If the preliminary assessment
indicates a suspected release of
hazardous substances that may
threaten human health or the envi-
ronment, EPA requires an inspec-
tion. The purpose of the SI is to
investigate the site firsthand and
determine if an HRS score should be
developed. The inspection begins
with a site visit and sample collec-
tion to define and characterize
further the problems at a site. The
primary objective of this in-depth
assessment of site characteristics is
to collect sufficient information to
document an HRS score to the
extent required for NPL listing. At
times, an expanded site inspection
has been necessary to fill data gaps
and to serve as a bridge between the
site assessment and remedial proc-
esses.
Approximately 12,800 Sis have
been conducted since Superfund's
inception. Figure 5 presents a
summary of accomplishments in the
site assessment program.
11
-------
1 Site Assessment Activities
Figure 5
Historical Superfund Site Assessment Accomplishments
33,000
1981 1982 1983
1984 1985 1986
Fiscal Year
1987 1988 1989 1990
Hazard Ranking System
In response to a CERCLA
mandate to establish a screening
mechanism, EPA developed a
mathematical approach to rate the
hazards of sites. This model, known
as the HRS, enables EPA to assess
the relative risk posed by sites in the
CERCLIS data base, and thereby
determine which sites should be
listed on the NPL. To evaluate risk,
the original HRS examined three
pathways of exposure: ground water,
surface water, and air. A composite
score for each site was developed by
considering three factors for each
pathway : likelihood of release,
waste characteristics, and targets.
EPA develops and refines the
score at each step of the site assess-
ment process, with the percentage of
hard data increasing as more
samples are taken. The score at each
stage of the process determines
whether or not a site will continue to
be considered for inclusion on the
NPL.
A revised HRS (rHRS) was
proposed in December of 1988, and
finalized in December of 1990. The
system was revised to portray more
accurately the degree of relative risk
to both human health and the
environment. The key changes in
this revision take into account, to the
extent possible:
• The population at risk
• The potential for drinking water
contamination
• The potential for direct human
contact
• The potential for ecosystem
destruction
• Damage that may affect the
human food chain
• Actual or potential contamina-
tion of ambient air.
The rHRS affects every stage of the
site assessment process. The
purpose of the HRS, however,
remains unchanged. It remains a
screening tool used to evaluate a
site's risk and determine its eligibil-
ity for the NPL. The HRS score
does not, however, provide an
indication of the feasibility, desira-
bility, or nature of the cleanup action
that will ultimately be undertaken.
NPL Listing Process
Sites of hazardous releases must
be included on the NPL in order to
be eligible for Superfund-financed
remedial action. The listing of sites
on the NPL is accomplished in one
of three ways. The most common is
for the site to score at least 28.50 on
the HRS. Second, each State is
given the opportunity to designate
12
-------
Site Assessment Activities
one site, which it considers its
highest priority, for the NPL.
Although less frequently used, the
third approach is to list sites for
which the Agency for Toxic Sub-
stances and Disease Registry
(ATSDR) has issued a health
advisory, that EPA determines pose
a significant threat to human health
and that EPA expects will be more
effectively addressed under the
remedial program, as opposed to
using its removal authority.
The promulgation of the revised
HRS is perceived as an opportunity
to implement far-reaching changes
in the NPL listing process and to
incorporate Total Quality Manage-
ment (TQM) tenets into the process.
The primary goal is to move sites
from discovery to listing in the 4-
year timeframe mandated by SARA.
The change most visible to the
general public will be the publica-
tion of two NPL Updates per year.
These offer the public an opportu-
nity to comment on a site and
receive responses from EPA, before
actually placing the site on the NPL.
Site Assessment
Accomplishments
The Agency has made substan-
tial progress in the past few years in
standardizing and streamlining the
site assessment process. These
efforts have resulted not only in an
overall improvement in the quality
and timeliness of assessment activi-
ties, but also in more effective State
involvement and greater consistency
nationwide.
13
-------
Remedial Activity
The Superfund remedial pro-
gram has evolved into a mature,
revitalized program aimed at prompt
action to address threats to human
health and the environment. Once
EPA places a site on the National
Priorities List (NPL), it becomes
eligible for long-term remedial
activity. Cleaning up these sites is a
long, complex process that may take
millions of dollars and many years
to complete. Remedial sites typi-
cally have multi-media contamina-
tion (soils, surface water, ground
water) by many different types of
chemicals. The sites often must be
broken up into several individual
projects to address all of the prob-
lems at the site, which may encom-
pass acres, or even miles. EPA is
developing new, innovative tech-
nologies to provide permanent, cost-
effective solutions at NPL sites.
The Remedial Process
The 1986 amendments to the
Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA) brought
new challenges to the remedial
program. EPA now strives toward
permanent remedies using alterna-
tive technologies to land disposal to
protect human health and the
an established, action-oriented program for
cleaning up the highest priority sites.
! Remedial actions at NPL sites
provide permanent, cost-effective
l_ solutions to the most serious
". hazardous waste sites. The primary
- goals of the remedial program are
:. to:
- * Protect human health and the
environment
i. • Address worst sites/worst
r problems first
i • Emphasize permanent reme-
~ dies using innovative treat-
* ment technologies.
environment. EPA is meeting this
challenge by creating systems for
information exchange, technology
development programs, and a
streamlined remedial process that
has addressed more than 1,000
remedial sites during the last 10
years.
The remedial process is com-
plex, requiring extensive data
gathering and analysis to character-
ize the scope of the problem and
potential threats to human health and
the environment, and to develop and
implement workable solutions to the
Figure 6
The Remedial Process
Remedial Investigation (Rl)
An assessment of the nature and extent of contamination (
and the associated health and environmentarrtsks ' , „ ;
Feasibility Study (FS) !
Development and analysis of the range of cleanup alternatives for the
site, according to the nine evaluation criteria; jjsually undertaken
concurrently with the Rl > !
*
Selection of Remedy
Selection of the remedial alternative for the site. This step includes;
Proposed Plan ' ' , <
Identifies the remedial alternative likely to be chosen for a Superfund
site and explains why it is the preferred alternative, arid allows „
for public comment '
Record of Decision (ROD)
The official report documenting the background information on the site
and describing the cfiosen remedy and how it was selected
|
Remedial Design (RD)
Preparation of technical plans and specifications
for implementing the chosen remedial alternative
+
Remedial Action (RA)
Construction or other work necessary to !
implement the remedial alternative
*
Operation & Maintenance (O&M)
Activities conducted at a site after a response action occurs
to ensure that the cleanup methods are working properly and ( '
to ensure site remedy continues to be effective
14
-------
Remedial Activity
problem. During the first phase of
the remedial process, the approach
to eliminating, reducing, or control-
ling risks at the site is conceived,
evaluated, and selected. Once this
remedy is approved, it is designed,
implemented, and monitored. The
five major steps that make up the
remedial process are shown in
Figure 6. Developing a workable,
permanent solution for a hazardous
waste site requires care—and
involvement from the community—
at each step of the process. The
overall remedial program goal is to
select a remedy that reduces or
eliminates the risks to people and the
environment, now and in the future.
Although the majority of
remedial activity in the past has been
funded through the Trust Fund, EPA
is aggressively pursuing responsible
parties to undertake and finance the
cleanup activities. Responsible
parties now conduct more than 60
percent of remedial actions, and that
percentage is expected to continue to
increase. In some cases, the respon-
sible parties clean up the sites
voluntarily, under the supervision of
EPA or the State. If no responsible
parties have been found, or if there
are problems getting them to act,
EPA will proceed using Trust Fund
monies and recover costs later.
The State may decide to conduct
and finance the cleanup by itself, or
may enter into a Cooperative
Agreement with EPA whereby the
State undertakes certain remedial
activities financed by the Fund. In
either case, EPA provides oversight
throughout the remedial action.
While the Hazardous Site Control
Division at EPA Headquarters
manages the overall remedial
program, the Remedial Project
Managers (RPMs) in each EPA
Region provide the day-to-day
direction and oversight of site
activity. Whether EPA or the State
has the lead in cleaning up a site,
CERCLA requires that the State
contribute 10 percent of the cleanup
costs for sites that were privately
owned or operated and 50 percent of
costs for sites that were owned or
operated by the public. In addition,
once EPA and the State have
certified that the remedy is working
properly, the State finances further
operation and maintenance.
Remedial Investigation
Once a site is placed on the
NPL, the lead agency must further
assess the site problems. Similar to
the initial site inspection prior to
listing on the NPL, this involves an
examination of site characteristics in
order to better define the problem.
The remedial investigation (RI),
however, is much more detailed and
comprehensive than the initial site
inspection. The RI is designed to
define the nature and extent of the
problem and to provide information
needed to develop and evaluate
cleanup alternatives. It is carried out
by a team of health and environmen-
tal scientists to determine the
existence and nature of any actual or
potential threat that may be posed to
human health or the environment,
and defines the boundaries or extent
of any contamination found at a site.
The Stauffer Chemical example (see
box, next page) illustrates the
complexity of site problems and data
collection needs.
Feasibility Study
EPA develops more than one
possible approach for Superfund
remedial action at a site, and care-
fully compares the advantages and
disadvantages of each approach.
These analyses of alternatives are
called feasibility studies (FSs).
In an FS, environmental engi-
neers and other technical staff
consider, describe, and evaluate
options for cleaning up the site,
using the data collected in the RI as
a basis and collecting additional
information as needed. Once the
cleanup alternatives are defined, the
feasibility study examines each
alternative according to nine criteria,
and portrays their effectiveness. The
kinds of questions an FS answers
are:
15
-------
Remedial Activity
.
Jj" ,^^,_,
1. Overall protection of human
health and the environment.
Will the remedy protect human
health and the environment;
how are risks eliminated or
controlled by the remedy?
2. Compliance with applicable
or relevant and appropriate
requirements (ARARs). Does
the remedy meet all of the
applicable requirements of
State and Federal environ-
mental laws and regulations?
These first two criteria are catego-
rized into a group called "threshold
criteria" because they are the
minimum requirements that each
alternative must meet to be eligible
for selection as a remedy. After
these criteria are applied, the FS
reviews:
3. Long-term effectiveness and
permanence. Does the remedy
protect human health and the
environment over time?
4. Reduction of toxicity, mobil-
ity, or volume. How well do
the treatment technologies
perform in reducing the threats
at a site?
5. Short-term effectiveness.
How well are the community
and cleanup workers protected
during the remedial action?
6. Implementability. What is the
technical and administrative
feasibility of a remedy, includ-
ing the availability of materials
and services needed to imple-
ment the chosen solution?
7. Cost. How much will the
remedy cost, including esti-
mated capital (e.g., supplies
and equipment, and contractor
costs) and operation and
maintenance costs?
§ Remedial Investigation At Stauffer Chemical
.
p:
The Stauffer Chemical site in Mobile County, Alabama, was the location of
chemical company operations from two adjacent plants. Waste from.the plants
included plant refuse, used samples, and solid wastes containing a variety of
herbicides and pesticides. The waste was placed in unlined landfills and waste-'
ponds, some of which drained into a local pond. The disposal practices^ both
sites contributed to ground water contamination. The owners installed moni-
toring wells and a system to treat the ground,water in the 1970s. Because the ^
ground water was not getting cleaner, "hi 1982 the State installed monitoring
wells, data from which formed the basis for EPA placing the site on the NPL.
EPA then informed the previous owner that an RI must be initiated at the, site. ',
During the RI, EPA examined the type and extent of the contamination on the „'
surface, and how the ground water was affected by the site contamination. 'The
surface contamination was .characterized J>y sampling of soils around the
landfills and ponds and sampling of the liquids in the ponds and 'other surface
water in the area. To investigate the ground water contamination, EPA ,(
sampled and analyzed the data from more than 40 water and .monitoring wells.
The results of the RI showed a range of threats, including ground water
contaminated with carbon tetrachloride and other contaminants, ponds contain-
ing contaminated soils and sludges, landfills containing a combination of
wastes that could be leaching into the ground water, and mercury detected in
the sediments of a nearby wetland. , - ,
I • Based on the RI, EPA had the information it needed to develop alternate
I solutions to the problems posed by the site. EPA discovered what contami-
r- nants existed, where they were located, and the level of contamination in each
f area. It was a long, difficult task of collecting the needed "information. It took
I more than 3 years from when EPA informed the previous owner of the site that
I an RI was necessary to when the RI report was completed. During the final
I phases of the RI, however, EPA began to conduct the next step hi the remedial
|2; process, the feasibility study. ,
16
-------
Remedial Activity
Evaluation criteria 3 through 7 are
known as the "primary balancing
criteria" that are used to identify
major trade-offs among the alterna-
tives. The last two criteria are:
8. State acceptance. Does the
State concur with, oppose, or
have no comment on the
preferred alternative?
9. Community acceptance.
Does the affected community
concur with, oppose, or have
no comment on the preferred
alternative?
These final two criteria, which are
determined after the proposed plan,
are called "modifying criteria"
because new information or com-
ments from the State or the commu-
nity may modify the preferred
alternative or lead to another re-
sponse action being considered.
Then the alternatives are compared
against each other to identify the
most effective remedy.
The public has the opportunity
to review the RI and FS reports.
These reports are placed in the site
information repository, which is
usually located at a local library.
RI/FS Accomplishments
The Superfund Amendments
and Reauthorization Act (SARA) set
mandatory deadlines for the com-
mencement of RI/FSs: by October
1989, EPA had to have started at
least 275 RI/FSs. EPA more than
met this ambitious goal as the
mandated number of RI/FSs were
underway 3 months ahead of the
deadline. By the end of FY90, EPA
had started RI/FSs at more than
1,000 sites and completed RI/FSs at
more than 600 sites. Figure 7 shows
the trend in RI/FS starts over the
past 10 years.
^Stalrtf^^hemkil/' Til > -^ •
tjj$*]&.$j^^
Mrfl1S~sH^:Ofr£iva;/JtU:irlp»rl-::mitYV.-ft\V*» ^lo •~,:i,'AI*+^,*,nt-A±*%~fl-; ? ~ '. i * : *,°
^hifollowiig ^tfmatiye^forjTgrbijitf^ deVe|6pepMthe; 1 •' - i
}f^^rbjse*d'^4?fefe'|e|uli|\of'thef(KI:j|/Jt^einb'a9tiqn;>1*T^av^V^^Jf*AMrt1 ^vi-»«r>>t*;W«'i-tf^lTn" A-Cf ^4-^. 'x «_*'Jl ; s ' ?"V
Figure 7
First RI/FS Starts
1200 -/
1000-
800-
•5
I
600-
» 400-
I
200-
1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
17
-------
Remedial Activity
The Stauffer Chemical site
illustrates the complexity of the RI/
FS process. Several initiatives,
however, are underway to streamline
and expedite the RI/FS process.
EPA is limiting the number of
remedial alternatives considered in
the RI/FS to those with clear poten-
tial effectiveness. This will reduce
resources spent on evaluating
alternatives that are impracticable.
In addition, EPA is in the process of
developing prototype RI/FSs and
remedy-selection models for site
situations that occur frequently, such
as municipal landfills, polychlori-
nated biphenyls (PCB) sites, and
wood-treating facilities. Such
prototypes will be used as a starting
point for planning and conducting
studies. RPMs can start with the
prototype and adapt it to the specif-
ics of their site.
Deciding Upon A Course
Of Action
Once the alternatives for
cleanup at a site have been evaluated
and a preferred alternative has been
decided, EPA formally requests
comment from the public by pre-
senting this information in the
Proposed Plan. The Proposed Plan
summarizes the alternatives ana-
lyzed in the detailed analysis of the
FS, the preferred remedy and the
rationale for that preference, any
proposed waivers to cleanup stan-
dards, and the position of the
support agency (e.g., the State) on
the Proposed Plan and preferred
alternative.
In the Stauffer Chemical Pro-
posed Plan, EPA documented the
analysis of the four alternatives
against the nine evaluation criteria
and against each other. EPA con-
cluded that Alternative #3—a
modified treatment system—passed
the first two criteria and provided
the best balance among the remain-
ing criteria, compared to the other
alternatives.
The public is given the opportu-
nity for a public meeting to discuss
issues related to the site and to
submit oral and written comments to
EPA during the 30-day public
comment period. Following receipt
of public comments and any final
comments from the support agency,
the remedial action is selected and
the rationale is documented in the
Record of Decision (ROD). The
ROD details the remedial action
plan for a site or operable unit,
certifies that the remedy selection
process followed the requirements in
CERCLA and the National Contin-
gency Plan (NCP), discusses the
technical details of the remedy, and
provides the public with a consoli-
dated source of information about
the site. Once the Regional Admin-
istrator or the Assistant Administra-
tor of the Office of Solid Waste and
Emergency Response signs the
ROD, it is released for informational
purposes and placed in the adminis-
trative record for the site. More than
700 RODs have been signed since
the program began. Figure 8 shows
the number of RODs that have been
signed since FY81.
The ROD has become much
more valuable than simply docu-
menting the remedy selected at one
site. It is a record of what to do in a
given set of conditions. EPA has
developed a detailed data base of
RODs, called the Records of Deci-
sion System (RODS). RODS serves
as an information base for similar
site conditions and to promote
national consistency among RODs.
Figure 8
RODs Signed
800 -f
600-
O)
55
CO
Q
O
DC
5 400-
3
Z
1
3
o
200-
1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
18
-------
Remedial Activity
Designing And Constructing
The Cleanup
Once the course of action has
been selected and approved, it is
time to design the remedial action
and carry it out. These are the last
phases of the remedial process:
remedial design (RD), remedial
action (RA), and operation and
maintenance (O&M). Unlike other
EPA programs which regulate
activities of the private sector, here
EPA actually manages the construc-
tion projects, designing the selected
remedy and implementing that
design.
RD is an engineering phase in
which technical drawings and
specifications are developed for the
subsequent RA, based on the
selected remedy documented in the
ROD. EPA assigns RD and RA
work to either the Alternative
Remedial Contract Strategy (ARCS)
contractors, the U.S. Corps of
Engineers, or the U.S. Bureau of
Reclamation, depending on the type
of remedy and the estimated cost of
the project. States and responsible
parties continue to manage the design
and construction of those Superfund
actions for which they have lead
responsibility. EPA RPMs provide
environmental oversight.
Remedial action projects may
appear to be like any other major
construction project, but in fact, the
presence of hazardous substances at
the site demands specially trained
engineers, scientists, and other
personnel; complex treatment equip-
ment; and special construction
planning and health and safety
procedures. In fact, a crucial element
of the RD/RA phase is the develop-
ment and implementation of the Site
Safety and Contingency Plans to
protect on-site personnel and sur-
rounding communities from the
physical, chemical, and/or biological
hazards of the site. These plans
include information on chemicals
present, equipment being used,
precautions to be taken, and steps to
take in the event of an emergency
situation at the site, including decon-
tamination procedures. Remedial
action projects also differ from the
usual construction project in that the
!fr— ^*-^-_: -*'
large volume of wastes to be treated
at many sites extends the RA
performance period over several
years and results in costs of tens of
millions of dollars.
After the RPM certifies that the
remedial action is complete and the
remedy is operational and func-
tional, the O&M phase begins.
O&M activities include ground
water and air monitoring, inspection
and maintenance of the treatment
equipment remaining on site, and
maintenance of any security mea-
sures such as signs and fencing. The
State or responsible party usually
assumes responsibility for these
activities,' while EPA is responsible
for oversight to ensure the site is
maintained and remains safe.
Remedial Action
Accomplishments
SARA set ambitious goals for
beginning remedial actions at
Superfund sites: by October 1989,
the program had to have started RAs
at 175 sites, and by 1991, another
200 RAs must be started. EPA met
the goal for RA starts in 1989.
Figure 9 shows the trend of RD and
RA starts over the past 10 years.
EPA has made remedial action a
top priority and has taken several
steps for continuous improvement in
the pace and quality of RAs at
Superfund sites. By streamlining the
RI/FS and remedy selection pro-
cesses—-through the use of prototype
RI/FS and remedy selection models,
an up-to-date ROD data base,
technical support from Headquar-
ters, and a peer review process—
today there are more sites in the
construction pipeline than ever
before. To address SARA mandates
for permanent remedies and the use
of alternative technologies where
possible, EPA has set up technical
19
-------
Remedial Activity
Figure 9
RD and RA Starts
I
800-1
600-
400-
200-
i 1 Remedial Designs
Remedial Actions
1981
1982
1383
1984
1985 1986
Fiscal Year
1987
1988
1990
Use Of Technologies At French Limited Site
llnnovative technologies are being moved out of the laboratories and into the field,
""as illustrated by the remedial alternative selected for the French Limited site in
"- Crosby, Texas. More than 300,000 cubic yards of industrial wastes from local
jpetrochemical companies were deposited in an unlined pit at this site. Sludge and
-soil from the waste pit were contaminated with PCBs, organics, and metals. A
'removal action was conducted at the site in 1982 to contain the wastes and to
^eliminate the immediate threats. The potentially responsible parties (PRPs) for the
^site then funded and prepared an RI/FS. In deciding among the various alterna-
lives for remedial action at the site, EPA had to choose one that provided the best
^balance among the nine evaluation criteria. In addition, EPA gave serious
^consideration to alternatives that met the preferences outlined in SARA: cleanup
alternatives that foster recycling or treatment of waste rather than land disposal;
E and remedies that employ treatment technologies that permanently and signifi-
cantly reduce the threats posed by the waste.
EPA concluded that a new treatment technology called bioremediation best met all
of the above criteria. Bioremediation uses micro-organisms to detoxify organic
matter. As a condition to selecting the remedy, EPA required the PRPs to conduct
a pilot study at the site before applying this treatment on the entire site. The pilot -
study had to prove that bioremediation was at least as effective as the other
alternatives at the site (mainly, incineration) and did not pose additional signifi-
cant threats during the process. The pilot study, which was conducted on a half-
acre section of the site, was very successful, reducing the threats posed by the
waste while posing no significant health threats during treatment. In addition to
being an effective remedy, bioremediation was supported by the State and
community and was half as costly as incineration. The site is presently in the RD
phase, with the RA anticipated to begin in 1991. Almost 50 percent of the
treatment remedies approved in RODs over the last 2 years involve innovative
" technologies, and that percentage is expected to continue to rise in the coming
years.
expert support systems and technol-
ogy evaluation programs to ensure
that existing knowledge and creative
ideas are being shared around the
country.
New Remedial Program
Initiatives
The remedial program is now an
established, action-oriented program
for identifying and cleaning up the
highest priority sites. The main
principles driving the program today
are:
Address worst sites/worst
problems first. After abating
immediate threats, EPA will
initiate the earliest remedial
work to address the highest
priority problems (e.g., immi-
nent threat to human health,
highly toxic, highly mobile
contaminants). In many cases,
EPA is taking action in deliber-
ate stages that will result in
continuous improvements until
the site is finally cleaned up to
human health and environ-
mental standards. This may
20
-------
Remedial Activity
include dividing the site into
operable units so that immedi-
ate attention is given to the
highest priority areas at a site.
Depending on site conditions,
EPA will take actions to
initially prevent exposure and
control risk; further actions will
be taken to reduce or eliminate
the risk. EPA is making sites
"cleaner"—while ensuring that
the stages of site cleanup are
consistent with the final
remedy—at as many NPL sites
as soon as possible.
Monitor and maintain sites.
In addition to quick action at a
site, EPA will monitor and
maintain sites over the long-
term to ensure that the remedy
at each site is fully protective
of human health and the
environment. As part of the
effort to monitor site condi-
tions, EPA will conduct, at
least every 5 years after the
initiation of the response
action, a review of all sites
where hazardous substances
remain on site. EPA also will
maintain the effectiveness of
the remedy over the long-term
by promptly correcting any
problems that are identified.
EPA will report annually to
Congress the results of all 5-
year reviews.
• Emphasize permanent
remedies using innovative
technologies. The ultimate
success of the Superfund
program depends on the
selection of remedies that
reduce risks to human health
and the environment in the
short term, and eliminate the
risks in the long term. This
initiative involves seeking
alternative technologies to land
disposal, developing new
technologies for more effective
cleanup, and ensuring that
these technologies provide
permanent protection to the
extent possible. SARA re-
quires that EPA give strong
preference to such remedies in
cleaning up Superfund sites.
EPA has been successful in creating
an environment conducive to
providing such remedies. This has
involved reducing regulatory and
policy barriers to the use of treat-
ment technologies and providing
extensive technical assistance,
expert advice, and information
transfer to make the best use of the
information that is available now
and that is under development. EPA
is aggressively supporting the
research, development, demonstra-
tion, and evaluation of new treat-
ment technologies to provide state-
of-the-art protection at Superfund
sites.
EPA has made great strides in
advancing the pace and quality of
long-term cleanup at Superfund sites
since the response to hazardous
chemicals found at Love Canal, New
York. The future of hazardous
waste cleanup is a challenge that can
and will be met. The Superfund
program has built up a sizeable
reservoir of knowledge in its first 10
years. The remedial program is in
place and information on effective
remedies is being developed and
shared throughout the program.
Cleanup activity at NPL sites is at
every stage of the remedial "pipe-
line"—sites that are in the Superfund
study and cleanup process. The
program will continue to grow and
address site problems through
aggressive goals, effective commu-
nication, and shared responsibility.
21
-------
The Enforcement Program
One of Superfund's major goals
is to have responsible parties pay for
and conduct cleanups at abandoned
or uncontrolled hazardous waste
sites. The foundation of Super-
fund's enforcement program is the
Comprehensive Environmental
Response, Compensation, and
Liability Act's (CERCLA) strict,
joint and several liability standard.
Under this standard, each poten-
tially responsible party (PRP)—
those owners and operators, waste
generators, and transporters at a
site—may be fully liable for all site
cleanup costs, regardless of waste
share or fault!
I In getting responsible parties to
" pay for or conduct site cleanups,
i EPA uses three, broad enforce-
* ment authorities to:
in Figure 10). PRPs now conduct
more than 60 percent of Superfund
remedial actions.
enforcement tools and reach settle-
ment agreements with responsible
parties.
One Superfund Program—Enforcement First.
EPA can negotiate settlements
with responsible parties to have
them conduct or pay for site clean-
ups. If negotiations fail, EPA issues
orders to responsible parties to
compel site cleanup. EPA also can
use Trust Fund monies to cover
cleanup costs and attempt to recover
the costs later through litigation. To
conserve Trust Fund dollars for
"orphan" sites, those where no
liable, financially-viable PRPs exist,
EPA's top priority is to use all its
The Enforcement Process
The enforcement process begins
immediately after a site is proposed
for listing on the National Priorities
List (NPL) (see Figure 11). At the
start of the NPL listing process, EPA
begins looking for PRPs who may
be liable for contamination at a site.
These PRP identification activities
are known as a PRP search. When
EPA has enough information to
identify a party as potentially
•~ • Reach settlements j
| *iiii .Issue orders i _ j
J • Recover costs.
When CERCLA was reauthor-
ized and amended by the Superfund
Amendments and Reauthorization
Act (SARA) in 1986, Congress
reinforced and significantly
strengthened the law's enforcement
provisions. SARA provided en-
forcement "tools" to facilitate
settlement negotiations, and en-
hanced the enforcement measures
available to EPA in the event that
responsible parties do not settle. In
addition, the Superfund Manage-
ment Review established the "One
Superfund Program—Enforcement
First" concept to encourage or
compel responsible party cleanups
rather than using the Trust Fund, and
to integrate all EPA response and
enforcement activities. The result
has been a seven-fold increase, over
the last 4 years, in the total value of
settlements to $3.7 billion (as shown
Figure 10
Total Value and Number of PRP Settlements
i
c
o
§•
o
cc
a.
£2
ITS
- £
& g
o •=
QI
l
4000.
3600.
3200.
2800.
2400.
2000.
£ £. 1600 .
o
3
O
•D
I
1200.
800.
400.
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989
Fiscal Year and Cumulative Number of Settlements
1990
22
-------
The Enforcement Program
Figure 11
Basic Enforcement Process
:', Issue
' Special '
, ", Notice '
Initiate?1'
; > Other ' ,.
>, Enforcement'
Options' '
RI/FS Negotiations
with a 60-90 Day
Response Moratorium
RD/RA Negotiations
with a 60-120 Day
Response Moratorium
Refer Section 106/107 Case to Department of Justice
Seek Treble Damages
Use Fund to Clean Up Site and Refer Section 107 Case
responsible for the site, EPA issues a
general notice letter to each PRP
notifying them of their potential
liability. As soon as PRPs are
identified, EPA begins exchanging
information with them concerning
site conditions, PRP connections to
the site, and other potentially
responsible parties.
Based on information obtained
during the PRP search and informa-
tion exchange process, EPA also
may issue special notice letters to
PRPs. The special notice letter
begins a formal negotiation period
and establishes a moratorium (60-
90 days for RI/FS negotiations, 60-
120 days for RD/RA negotiations)
on certain response and enforcement
activities. If within 60 days, PRPs
make a "good-faith offer" to conduct
the response action, the moratorium
may be extended to provide addi-
tional time for reaching a final
settlement. An administrative
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-------
The Enforcement Program
record for a site, which includes all
documentation relating to the
selected remedy, is usually estab-
lished as soon as the site is discov-
ered. The administrative record is
the basis for any judicial review of a
settlement or the selected remedy by
the court.
Settlement agreements may be
reached to conduct a remedial
investigation/feasibility study (RI/
FS) or a remedial design/remedial
action (RD/RA). EPA has a variety
of enforcement tools provided by
SARA to encourage PRPs to settle
(see box on previous page). If
PRPs do not agree to conduct the RI/
FS, they may settle at a later date to
conduct the RD/RA. However,
PRPs who are actively involved in
site work from the time they receive
a general notice letter, and who
conduct the feasibility study, can
have more input on the remedy that
is selected. Figure 12 summarizes
PRP involvement in response actions
since Superfund's inception.
A settlement agreement to
conduct an RI/FS is usually formal-
ized in an administrative order on
consent (AOC). AOCs are issued
under EPA's administrative authority
and legally bind both EPA and the
settling PRPs. Although AOCs are
not lodged in court, the Department
of Justice (DOJ) may review certain
RI/FS settlements. RD/RA settle-
ments, however, must be lodged in
court by DOJ, in the form of a
consent decree. For all settlements,
DOJ represents EPA in actions
brought by responsible parties.
If PRPs do not settle, EPA can
either issue orders to force liable,
financially viable PRPs to conduct
the response action, or spend Trust
Fund monies and recover the costs
from the PRPs later. For RD/RAs,
EPA routinely issues unilateral
administrative orders (UAOs) to
force non-settling PRPs to imple-
ment the remedy themselves. UAOs
are legally binding and do not
require EPA to sue PRPs in court to
become effective. In addition,
UAOs do not provide PRPs some of
the advantages of settlements, such
as protection from other PRPs or
other third parties seeking contribu-
tion for response costs. Non-
compliance with a UAO can result
in civil penalties of $25,000 per day,
and if Trust Fund monies are spent,
EPA may seek triple the cost of the
response action (treble damages) in
cost recovery litigation. Finally, if
PRPs do not comply with a UAO,
EPA may sue in court and obtain a
court order forcing them to conduct
the response action and to reimburse
EPA for its oversight costs.
Figure 12
Trend in PRP-Financed Response Actions
g
I
-------
The Enforcement Program
EPA also has the option to
spend Trust Fund monies to conduct
the cleanup, and then recover the
costs from the responsible parties.
Under CERCLA, any past and
present owner and operator at a site,
as well as waste generators and
transporters, can be held fully liable
by the courts for complete cleanup
costs. During a response action,
EPA develops a cost recovery case
and refers it to DOJ for litigation.
Since 1980, EPA has referred 391
civil cases seeking $644 million in
past costs to DOJ (see Figure 13).
Aggressive enforcement efforts
are necessary to the Superfund
program because the cost of clean-
ing up all the sites on the NPL far
exceeds the money available in the
Trust Fund. For its part, EPA has
developed critical guidance and
model administrative documents,
produced a draft cost recovery
regulation to expedite cases, and
hired 500 new personnel based on
recommendations in the 1989
Superfund Management Review to
push sites through to cleanup. With
the enforcement program's infra-
structure in place and the implemen-
tation of the "One Program—
Enforcement First" concept, the
involvement of PRPs in Superfund
cleanups will continue to grow.
Figure 13
Total Value and Number of
Section 107 Cost Recovery Referrals
«o 700-i
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8 -jy
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$21 $34 70
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2 3 / -%(£ ^|
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$459
312
/ Ii
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223
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$131
134
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i
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i
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i
s
s
s
1
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989
Fiscal Year and Cumulative Number of Settlements
1990
25
-------
Public Participation In Decisionmaking
Like every component of the
Superfund program, the community
relations initiative has grown and
matured since Superfund's inception
in 1980. From the beginning, EPA
recognized the importance of
community input and involvement in
the hazardous waste site cleanup
process. Agency staff at Headquar-
ters and in the field realized that the
most innovative cleanup technology
could not be considered successful if
j „
i Superfund community relations
i activities are important to:
f
t • Promote'two-way
J communication
Provide input to technical
decisions
Discover useful site
information
Focus and resolve conflict.
it was not accepted by the "affected
public"— the people who live and
work near the hazardous waste sites.
In the early days of the program,
community relations activities
generally occurred
on an informal, ~~———
site-specific basis.
There were no
required activities;
specific communi- ^_____^_1
cation and infor-
mation needs of the
interested citizens determined each
site's public participation initiative.
As the program evolved, the Agency
formulated policy statements and
developed program guidance. The
1982 National Oil and Hazardous
Substances Pollution Contingency
Plan (NCP) contained requirements
for community relations at all
remedial sites and for removals
lasting more than 120 days. In
1986, the Superfund Amendments
and Reauthorization Act (SARA)
added legislative requirements and
in 1989, the Superfund Management
Review made recommendations to
further improve the community
relations program. Throughout the
years, one aspect of the program has
been maintained—EPA still con-
ducts community relations activities
on a site-specific basis. Although
today's program has many required
activities, each one is tailored to the
specific issues of importance to the
public, the level of concern, the
history of public involvement, and
the economic and social structure of
the community.
Achieving Public
Participation
Community relations activities
have occurred at every site at which
an RI/FS has been started and at all
removal sites where time has
allowed. Community relations
efforts promote two-way communi-
cation among members of the
public, State and local officials,
other Federal agencies such as the
Community relations efforts promote
two-way communication.
U.S. Corps of Engineers, the U.S.
Coast Guard, and the Department of
Defense, and EPA.
The community relations
program encourages communication
with affected citizens and participa-
tion in decisionmaking. It has three
main objectives:
• Give the public the opportunity
to comment on and provide
input to technical decisions.
26
-------
Public Participation In Decisionmaking
• Inform the public of planned or
ongoing actions and keep them
apprised of the nature of the
environmental problem, the
threats it may pose, the re-
sponses under consideration,
and the progress being made.
• Focus and resolve conflict.
Conflict may be unavoidable in
some circumstances, but it can
be constructive if it brings into
the open alternative viewpoints.
Every phase of the technical
schedule for site cleanup has corre-
sponding community relations
requirements. For a remedial site, a
Community Relations Plan (CRP)
must be developed before RI/FS
field work begins. The CRP is the
"work plan" for community relations
activities that EPA will conduct
during the entire cleanup process. In
developing a CRP, Agency staff
members conduct interviews with
State and local officials and inter-
ested citizens. Through this one-on-
one interaction, EPA learns about
citizen concerns, site conditions, and
local history. This information is
used to formulate a schedule of
activities designed to keep citizens
apprised and to keep EPA aware of
community concerns. Typical
community relations activities
include public meetings, at which
EPA presents a summary of techni-
cal information regarding the site
and citizens can ask questions or
comment; small, informal public
availability sessions at which EPA
representatives make themselves
available to citizens; and develop-
ment of fact sheets, which the
Agency distributes periodically to
keep citizens up-to-date on site
activities.
Part of every CRP is the estab-
lishment of an information reposi-
tory. EPA is required to set up a file
of information related to the site in a
building accessible to citizens.
Usually housed in a library or town
hall, the repository contains reports,
studies, fact sheets, and other
documents containing information
about the site. EPA continually
updates the repository and must
ensure that the facility housing the
file has copying capabilities.
After the RI/FS is completed
and EPA has recommended a
preferred cleanup alternative, the
Agency sends to all interested
parties a Proposed Plan outlining the
cleanup technologies that were
studied and explaining why EPA
prefers one remedy over the others.
At this time, EPA also begins a
public comment period during which
citizens are encouraged to submit
comments regarding all alternatives.
Once the public comment period
ends, EPA develops a Responsive-
ness Summary, which contains EPA
responses to public comments. The
Responsiveness Summary becomes
part of the Record of Decision
(ROD), which provides official
documentation of the remedy chosen
for the site.
Community relations activities
occur at specific points in the
remedial process, as shown in Figure
14. In addition to meeting these
Federal requirements, EPA makes
every attempt to ensure that commu-
nity relations is a continuing activity.
designed to meet the specific needs
of the community.
What EPA Has Learned
Superfund participants at the
Federal, State, and local levels
acknowledge the importance of
public participation in the Superfund
program. Because it is such an
integral part of all cleanup opera-
tions, EPA is constantly striving to
improve its communications with
the public. Agency experience over
the past 10 years has yielded general
conclusions about the nature of
public involvement in hazardous
waste issues, and, in turn, about the
most helpful approaches to public
participation. EPA has learned, for
example, that its decisionmaking
ability is enhanced by actively
soliciting comments and information
from the public. In addition, experi-
ence has shown that the earlier EPA
establishes a working relationship
with citizens near a site, the greater
chance there is for trust and confi-
dence to develop between the
parties. EPA also has found that
communities often are able to
provide valuable information on
local history, citizen involvement,
and site conditions. Establishing a
dialogue between Agency staff and
citizens, therefore, allows both the
public and EPA access to important
information. This dialogue can help
identify citizen concerns about the
site, enabling EPA to be most
responsive to community needs.
By planning at the outset for a
high level of citizen involvement,
EPA has usually been able to avoid
the delays in cleanup which might
otherwise arise from uninvolved and
disaffected citizens. Consequently,
27
-------
Public Participation In Decisionmaking
Figure 14
Overview of EPA Community Relations Requirements
Decision Point
(Technical Process)
EPA Community
Relations Requirements
Opportunities For
Participation
NPL Listing
Publish the proposed additions to the NPL
in the Federal Register: solicit comments
through a public comment period
Submit comments in support of or
opposition to the site being listed on the
NPL
RI/FS and
Administrative Report
Develop Community Relations Plan (CRP)
Establish information repository and
administrative record
Announce and describe the TAG Program
Participate in on-scene interviews; submit
names for mailing list
Periodically review site-related information
Assess community need for TAG; if
appropriate, submit application
Proposed Plan
Notify public of Proposed Plan; make plan
available in information repository and
administrative record
Provide opportunity for public meeting
Conduct a minimum 30-day public
comment period
Review alternatives
Request meeting; gain further insight into
cleanup alternatives
Submit written or oral comments on the
alternatives
ROD
Prepare Responsiveness Summary; make
it and ROD available in information
repository and administrative record
Review and comment on EPA decision
document
RD/RA
Revise CRP, if necessary
Make remedial design available in
information repository and administrative
record
Prepare fact sheet on remedial design
Provide opportunity for public meeting
Participate in on-scene interviews
Review remedial design
Read fact sheet
Request meeting; gain further insight into
design
NPL Deletion
Place copies of information supporting the
proposed deletion in the information
repository
Publish a notice of intent to delete in the
Federal Register and solicit comments
through a minimum 30-day public
comment period
Respond to comments and include
responses in the final deletion package in
the information repository
Review information regarding proposed
deletion
Submit comments in support of or
opposition to the site being deleted
Review the final deletion package
28
-------
Public Participation In Decisionmaking
Agency staff members are committ-
ed to listening to citizen concerns
and fully involving the public in the
decisionmaking process "early, often
and always."
The Technical Assistance
Grant (TAG) Program
One of the most significant
accomplishments of the Superfund
community relations program is the
awarding of technical assistance
grants or TAGs. Established by
Congress in-1986, the TAG program
helps ensure that affected individu-
als are well informed about the
conditions and activities at
Superfund sites in their communi-
ties. The program provides groups
with grants to hire independent
technical advisors who can help
them understand technical informa-
tion related to cleaning up a site.
One grant of up to $50,000 is
available for each site as long as the
site is listed or has been proposed
for listing on the NPL, and EPA has
begun its response action at the site.
If the site is a complex one, it is
possible to receive additional
funding. To date, EPA has
awarded 40 grants across all
ten EPA Regions, as shown
in Figure 15.
Groups eligible to
receive TAGs are groups of
individuals who live near the
site and whose health,
economic well-being, or
enjoyment of the environ-
ment is directly threatened.
Such groups could be
existing citizens' associa-
tions, environmental or
health advocacy or similar
organizations, or coalitions of such
groups formed to deal with commu-
nity concerns about a hazardous
waste site and its impact on the
surrounding area.
In general, grant funds may be
used to hire technical advisors to
increase citizen understanding of
existing information about the site,
or that is developed during the
Superfund cleanup process. Grant
monies are often used to pay techni-
cal advisors to review site-related
documents, meet with the recipient
Figure 15
Technical Assistance Grants
Accomplishments
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K\;
PP 0= \*APJ, *?"; 't -o-'i
group to explain technical informa-
tion and interpret technical informa-
tion for the community.
EPA has Community Relations
Coordinators and TAG Coordinators
at Headquarters and in each EPA
Region. The addresses and tele-
phone numbers of Headquarters and
Regional Offices are presented at the
end of this document.
29
-------
Roles Of States And Indian Tribes
States continue to take lead
responsibility for Superfund re-
sponse at many sites, and that
number is expected to increase
significantly as individual State
hazardous waste programs mature.
For example, States have led nearly
300 remedial investigation/feasibil-
ity studies (RI/FSs) and more than
80 remedial actions (RAs) since the
program's inception, with the most
dramatic increase in Superfund
activity happening during the last 4
years.
States and political subdivisions
(such as county governments) with
the necessary technical and manage-
ment expertise are authorized to lead
cleanup efforts. The Comprehensive
Environmental Response, Compen-
sation, and Liability Act (CERCLA)
also requires EPA to coordinate with
States when the Federal government
leads site response.
jllll*IiMlliiiiaiaiSS?i™ n3S|
t State and Indian Tribal involve-
J mcnt in the Superfund program is
| based on:
t • Requirements found in the
i Superfund Amendments and
-i
•' - - ----- i
I • Procedures outlined in the j
| National Oil and Hazardous "f
I Substances Pollution Contin- ",
"- gency Plan (NCP) and
§ Superfund Administrative i
' Regulation, and
15 •
I • Formal agreements between
j States, political subdivisions, "
I or Indian Tribes and EPA. ^
In the earlier days of the Super-
fund program, EPA focused on
involving States in individual
remedial activities, while the
Agency developed a better under-
standing of the requirements for
effective response. EPA relied on
comprehensive guidance for State
participation because the original
Superfund law provided few proce-
dures for getting States involved.
The enactment of SARA strength-
ened and broadened State involve-
ment in Superfund by specifying the
points at which State participation is
required. SARA outlines minimum
requirements for involving States in
virtually every phase of Superfund
decisionmaking. As a result, States
can participate in enforcement,
removal actions, site assessment,
and remedial activities. SARA also
enables EPA to help States increase
their role in site-specific response by
funding their non-site-specific,
general Superfund programs.
SARA extends this EPA/State
interaction to Indian Tribes, as well.
EPA must treat Indian Tribal
governments substantially the same
as States, which may either lead a
response or provide support when
EPA leads the activities. To be
considered the same as States, an
Indian Tribe must be Federally
recognized by the Bureau of Indian
Affairs, have jurisdiction over a site
in EPA's data base of hazardous
waste site information or a site on
the National Priorities List (NPL),
and have a Tribal governing body
that is promoting health, safety, and
welfare of the affected population.
Local governments also play an
important role during a Superfund
cleanup. Localities may lead a
response action and often provide
important public safety measures
during emergencies, for which they
may receive some financial assis-
tance under the Local Governments
Reimbursement (LGR) program.
The LGR program is intended to
ease the financial burden on local
governments from conducting
temporary emergency measures in
response to a hazardous substance
threat. The program offers assis-
tance of up to $25,000 per response
directly to local governments.
Statutory And Regulatory
Framework
CERCLA authorizes the Federal
government to lead hazardous waste
response activities at a site, or to
transfer the necessary funds and
management responsibility to a State
(State-lead), a political subdivision
of a State, or a Federally recognized
Indian Tribe. Regardless of which
level of government leads a re-
sponse, the State must make certain
assurances to EPA. As part of these
assurances, the State must pay part
of the cleanup costs. If the site was
privately operated at the time of the
hazardous substance release, the
State must pay 10 percent of the
costs of the actual cleanup. If the
State or a locality operated the site
when hazardous substances were
disposed there, it must pay 50
percent or more of all Federal
response costs.
In addition to helping defray
some of the costs, a State must also
ensure the availability of a disposal
facility for hazardous materials
removed from a site during cleanup,
as well as ensure its capacity to
adequately handle all hazardous
wastes generated within the State
over 20 years, starting from 1989.
Operation and maintenance of the
selected remedy once the cleanup is
completed and is proven to be
running smoothly also is the respon-
sibility of the State as part of its
assurances to the EPA.
The NCP (Subpart F) clarifies
how EPA will achieve substantial
and meaningful involvement by each
State and Indian Tribe. The
Superfund Administrative Regula-
tion (40 CFR Part 35 Subpart O)
defines how EPA can transfer funds
for site response to State, political
subdivision, and Indian Tribal
Superfund programs to support the
development of their programs'
30
-------
Roles Of States And Indian Tribes
goals and maintain their effective-
ness to respond to hazardous waste
threats.
Promoting State And Indian
Tribal Involvement
EPA has developed four ways to
involve States, Indian Tribes, and
political subdivisions in Superfund:
• Cooperative Agreements:
Cooperative Agreements
transfer funds from EPA to
States, political subdivisions, or
Indian Tribes to lead site-
specific responses or to cover
the costs of their participation
in Federal-lead or other
CERCLA activities. A Coop-
erative Agreement also is the
legally binding document to
obtain required State cost
shares and CERCLA section
104 assurances when a State or
Indian Tribe leads a remedial
action. Under a Cooperative
Agreement, the State, political
subdivision, or Indian Tribe can
lead a response at a site or
several response actions at one
or more sites.
• Superfund State Contracts
(SSCs): SSCs are joint, legally
binding agreements between a
State or Indian Tribe and EPA
that assure the transfer of cost-
sharing funds when EPA is
leading a Superfund response
action. SSCs document that
States or Indian Tribes have
made all required assurances
under CERCLA, as amended.
They also can be used to
specify required State involve-
ment during a political subdivi-
sion-lead response.
• Core Program Cooperative
Agreements: EPA created
Core Program Cooperative
Agreements to provide general
Superfund,program support
funds to States and Indian
Tribes. Core Program funding
defrays the cost of essential
State and Indian Tribe activities
that cannot be accounted for on
a site-specific basis, but are
essential to an active role in
CERCLA implementation. For
example, States and Indian
Tribes have used Core Program
Cooperative Agreements to pay
for administrative and clerical
salaries, computer resources,
program management,
recordkeeping, and training.
• Superfund Memoranda of
Agreement (SMOAs): EPA
developed SMOAs to define
the working Superfund partner-
ship between EPA and a State
or Indian Tribe. ASMOAisan
optional document that speci-
fies the procedures that EPA
and a State or Indian Tribe will
use to implement CERCLA and
the NCP. These procedures
then serve as the basis for site-
specific Cooperative Agree-
ments or SSCs.
State And Indian Tribal
Accomplishments
The number of State-lead
activities is greatest in the site
assessment program. States have
identified more than 32 percent of
the sites that are currently listed in
EPA's inventory of hazardous waste
sites. To date, States have assumed
responsibility for approximately
20,500 preliminary assessments
(PAs), or nearly 60 percent of the
national total. They have completed
19,500, or more than 58 percent of
all PAs conducted within the
Superfund program. States also
have completed more than 4,500 site
investigations (Sis) and Hazard
Ranking System calculations, 32
percent of the total number of Sis
that have been completed nation-
wide. Two Indian Tribal govern-
ments also have been awarded
Cooperative Agreements to conduct
site assessment activities.
States have made an equally
significant contribution to remedial
activities at hazardous waste sites
(see Figures 16 through 18). Since
1980, States have completed 139 RI/
FSs, 51 remedial designs (RDs), and
Each State and Indian
Tribe may determine the
role it will take in
Superfund.
27 RAs. This represents 16 percent,
14 percent, and 15 percent of total
nationwide RI/FS, RD, and RA
completions, respectively. In
addition, the number of ongoing
activities led by States has grown
steadily over time. This increase
suggests a strong State commitment
toward long-term cleanup activities.
Four Indian Tribes also have been
awarded Cooperative Agreements to
conduct support agency activities
during Federal-lead remedial
response activities.
Core Program funds have also
made a critical difference in increas-
ing State and Indian Tribal Super-
fund capabilities. The Core Program
began in FY87 with three States
participating in pilot activities.
Today, all States, Territories, and
Federally recognized Indian Tribes
are eligible to participate, and 44
States, the Territory of Puerto Rico,
and three Indian Tribal governments
are active in the program. Through
the Core Program, each State,
Territory, and Indian Tribal govern-
ment has the opportunity to deter-
mine the long-term role it will take
in Superfund.
31
-------
Roles Of States And Indian Tribes
i
State Superfund Program Success Stories:
Core Program Funds Make A Difference...
Mississippi's State Superfund Program has come a long
way since 1987. From the passage of CERCLA until mid-
1987, Mississippi had only four full-time staff and one
parMfme sujpervlson Response operations were limited.
Iii 1988, however, the State entered into a Core Program
Cooperative Agreement with EPA which allowed Missis-
sippi to expand its program and, therefore, its effect on
cleaning up hazardous waste sites. This expansion, which
continued with funding provided by Cooperative Agree-
ments with the EPA in 1989 and 1990, included increasing
professional staff dedicated to Superfund response four-
fold, and subsequent participation in site assessment
activities. In addition, the State's ability to take aggres-
sive "en force rhentac lion s against individuals or firms
responsible for contributing to abandoned hazardous waste
sites improved.
Mississippi is currently pursuing enforcement activities
under administrative orders at 100 sites, representing
nearly one-third of the Mississippi sites listed in the
CERCLA Information System (CERCLIS). The State has
developed an enforcement action guidance document
consistent with the NCP, entered into a SMOA with EPA,
signed a Cooperative Agreement to provide funds to
review technical documents and actions at its two NPL
8ite's7enteire3 mtolfie'riation's'ifirst SMOA with the
Department of Defense (DOD) to oversee response actions
at abandoned DOD facilities, and is in the final stages of
negotiating a similar SMOA with the Department of
Energy.
Political Subdivisions Can Play A Critical Role...
South Adams County, Colorado needed clean water. As
part of a remedial action, EPA planned to provide local
citizens with a permanent alternate water supply to take
the place of contaminated existing sources. Design and
construction of this were expected to take a substantial
period of time to complete, and EPA was unable to
provide an interim alternate water supply until the perma-
nent one was in place. As a result, South Adams County
offered to take the lead for the interim cleanup measures.
The County entered into a political subdivision-lead
Cooperative Agreement with EPA which provided an
Interim watersugply that included hooking up residences' .
and implementing other interim measures to protect the
human health and the environment. Through its involve-
ment in the Cooperative Agreement, South Adams County
gained significant experience in site remediation activities
as well as in the whole Superfund process. The County
continued to play an active role in site actions throughout
the entire remedial action.
Figure 16
State-Lead Remedial Investigation/
Feasibility Study Starts
300
250
150
100
50
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
Figure 17
State-Lead Remedial Design Starts
s
tn
•8
1
E
o
120
100
80
60
40
20
7
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
Figure 18
State-Lead Remedial Action Starts
100
£ 80
£
S>
•8
I 60
E
40
20
z
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
32
-------
Management Infrastructure
^l^e'lor^^lwg;^;.^
EPA spent most of the first
decade of Superfund getting its
house in order, and developing and
enhancing the organizational struc-
ture and management systems
necessary to get the job done, with
cleanup progress accelerating by the
end of the decade.
Judging the seriousness of
potential threats at each Superfund
site and determining the best solu-
tion is a complex task. It requires a
sophisticated infrastructure of
management systems and scientific
and technological expertise. One of
Superfund's most significant accom-
plishments during its first decade
has been the development of such a
network. EPA has developed and
continues to streamline management
procedures and policies for admini-
stering the Superfund program.
In addition, efforts by the
scientific and engineering commu-
nity to solve the unique problems
presented by Superfund sites have
resulted in the development of a
wide range of new techniques for
treating hazardous substances and a
greater understanding of their health
effects.
Building The Program
In 1980, the nation committed
itself to a major Federal effort to
tackle its hazardous waste problem.
From this mandate, EPA designed,
enacted, and put into place the
Superfund program—its contracting
mechanisms, management informa-
tion systems, accounting procedures,
scientific, legal and technical
protocols, and program planning and
evaluation measures. The early slow
pace of the program stemmed, in
part, from the difficulty of moving
ahead before program policies,
procedures, roles, and responsibili-
USEPA
COMBUSTION RESEARCH FACiUTY
ties were clearly defined. Today, the
management foundation of
Superfund is solidly in place and is
continually being refined and
enhanced.
Further, the Agency coordinates
the efforts of EPA staff in its Wash-
ington, D.C., Headquarters, its front-
line staff in ten Regional offices
across the nation, State government
staff, contractors, and private parties
who assume responsibility for
cleanup. Comprehensive informa-
tion systems-have been developed,
not only to manage the large sums of
money being spent and the efforts
underway at hundreds of projects
simultaneously, but also to exchange
state-of-the-art technical information
on chemicals, technologies, safety
procedures, and sources of assis-
tance. The Superfund program also
has initiated a new strategic plan-
ning system aimed at identifying and
prioritizing critical activities over a
5-year period. This system comple-
ments the Agency's overall planning
activities for achieving cross-
program integration and comprehen-
sive risk reduction.
Managing For Continual
Improvement
EPA has realized, however, that
its infrastructure must continue to
evolve, and has taken innovative
steps to improve its performance.
First, Total Quality Management
principles are now being applied in
all parts of the Superfund program to
clearly define program customers
and requirements, produce error-free
work, improve operations constantly
and forever, and effectively manage
the workload by preventing waste
and inefficiency. Another signifi-
cant step was completion of the
Agency's Superfund Management
Review in 1989. The Management
Review of the Superfund Program is
providing the strategy for a second
decade of increased program integ-
rity and a full "pipeline" of site
33
-------
Management Infrastructure
activity. This review provided more
than 50 recommendations for
addressing fundamental issues
facing the program:
• Reducing environmental risks
from a growing list of sites
that present new complexities
• Making defensible cleanup
decisions, sometimes without
complete knowledge of
environmental and health risks
• Maximizing the use of treat-
ment technologies, recogniz-
ing that many of these tech-
nologies are new and untested
in the field
• Making efficient use of
limited resources.
Today, EPA has completed nearly
all of the more than 120 manage-
ment improvement measures identi-
fied in this self-evaluation.
One of the most significant
accomplishments of the Superfund
Management Review is the develop-
ment of a Long-Term Contracting
Strategy for the Superfund program.
The Agency's purpose in developing
this strategy was to analyze the long-
term contracting needs of the
program, and design a portfolio of
Superfund contracts to meet those
needs over the next 10 years.
Completed in September of 1990,
the strategy will help integrate
enforcement and site cleanup
activities, enhance competition by
reducing the size of contracts and
creating more opportunities for
smaller businesses, and provide
greater management flexibility and
improved oversight and cost control.
Communicating Program
Results
Many have judged the success
of the Superfund program by the
number of sites removed from the
NPL. While that number reflects one
measure of progress, it does not
begin to tell the entire story. Success
for Superfund is more appropriately
measured in terms of the successive,
incremental cleanup steps that
quickly reduce threats to people and
the environment and ultimately
provide long-term protection.
Instead of concentrating on
continuous and complete cleanup of
a few major sites, the Agency will
now dedicate resources to ensure the
greatest degree of public safety at the
Developing The Science
Behind The Solutions
The Superfund program has
explored new frontiers in the applied
sciences. To address hazardous
substance problems, Superfund
response personnel must understand
how complex mixtures of chemicals
travel through the soil, ground
water, and the air. This has been a
long and complex task for environ-
mental scientists, requiring a combi-
nation of real world field sampling
results and theoretical models.
... dedicate resources to ensure the greatest degree
of public safety at the largest number of sites.
largest number of sites. The longer
process of total site cleanup on a
national scale will move forward
steadily at the same time as incre-
mental progress is being made at'
sites. Deleting a site from the NPL
will become a distant goal, as EPA
focuses on the more meaningful task
of solving immediate problems that
affect human health and safety.
Superfund has made real envi-
ronmental gains and has developed a
new means of portraying progress.
These new measures, known as
environmental indicators, describe
tangible environmental improve-
ments in terms that are useful and
familiar. For example, progress in
making sites safer can be viewed in
terms of efforts to control immediate
threats (such as providing an alter-
nate water supply). Progress also can
be measured in terms of making sites
clean (such as reaching goals for
permanent site cleanup). A third way
to characterize Superfund progress is
EPA's efforts to bring technology to
bear on site problems. As shown in
Figure 19, on the following page, the
Superfund program is using technol-
ogy to remove contamination from
the environment.
34
EPA's knowledge of how contami-
nants enter and travel through
environmental media has increased
significantly as the Agency has
evaluated more and more sites for
possible Superfund response.
Of even greater complexity has
been the task of estimating the
degree to which human health is
endangered by Superfund sites.
Typically, people at risk because of
a waste site have been exposed to
very small quantities of hazardous
substances over a prolonged period,
and the health effects of these
substances usually do not surface
until long after the exposure has
taken place. During the first decade
of the Superfund program, EPA and
other Federal agencies, particularly
the Agency for Toxic Substances
and Disease Registry (ATSDR)
within the Department of Health and
Human Services, focused on assess-
ing risks at specific sites and refin-
ing the risk assessment process. As
a result of the 1986 amendments to
the Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA), ATSDR
also began preparing toxicological
profiles for the most frequently
-------
Management Infrastructure
found substances at Superfund sites,
and completed health assessments
for all National Priorities List (NPL)
sites within 1 year of their inclusion
on the NPL.
Encouraging New
Technology For Risk
Reduction
The 1980 Superfund law did not
have specific provisions for research
and development of engineering
techniques and equipment for
handling, containing, treating, and
disposing of hazardous substances.
The Superfund Amendments and
Reauthorization Act (SARA)
required EPA to establish a formal
research and development program,
including demonstration programs
for technologies that offer alterna-
tives to conventional methods of
handling site cleanups, and favoring
methods that lead to the destruction
or recycling of wastes rather than
land disposal. SARA also called for
training programs for hazardous
substance response and research.
In 1986, EPA began the Super-
fund Innovative Technology Evalu-
ation (SITE) program to promote the
development and use of innovative
technologies to clean up Superfund
sites across the country. Now in its
fifth year, SITE is helping to provide
the treatment technologies necessary
to implement new Federal and State
cleanup standards aimed at perma-
nent remedies rather than quick
fixes. The SITE program is really
three related programs: the Demon-
stration Program, the Emerging
Technologies Program, and the
Measurement and Monitoring
Technologies Program.
To date, the major focus of the
SITE program has been on the
Demonstration Program, which is
designed to generate engineering
and cost data on selected, innovative
technologies. In this program,
Figure 19
Waste Removed From The Environment
Pathway
Volumes Addressed
Polluted Land Surface:
Soil 4,130,000 cubic yards
Solid Waste 5,270,000 cubic yards
Liquid Waste 1,000,000,000 gallons
Polluted
Ground Water: 3,880,000,000 gallons
Polluted
Surface Water: 104,000,000 gallons
technology developers are respon-
sible for demonstrating their innova-
tive systems at selected sites, while
EPA is responsible for sampling,
analyzing, and evaluating all test
results. The information gathered
during the demonstrations is used in
combination with other data as a
basis for selecting the most appro-
priate technologies for the cleanup
of Superfund sites. More than 52
developers are now active partici-
pants in the Demonstration Program
for field-scale technologies. They
represent a wide variety of innova-
tive technologies, from thermal
treatment and bioremediation to soil
washing, solvent extraction, and in-
situ stripping. Since the first dem-
onstration in 1987, EPA has con-
ducted 19 demonstrations.
The Emerging Technologies
Program provides 2-year funding to
developers of emerging technologies
to support bench-scale and pilot
testing of innovative treatment tech-
nologies. EPA has accepted a total
of 31 bench- and pilot-scale technolo-
gies to date. Laser technology is one
method being investigated for use in
reducing the toxicity of wastes at
Superfund sites.
Lastly, the Monitoring and Meas-
urement Technologies Program
supports the development and demon-
stration of innovative field-ready
technologies that detect, monitor, or
measure hazardous substances in the
air, surface water, soil, subsurface,
and in waste materials and biological
tissues. This program began in earnest
in 1990, and four demonstrations have
been completed. EPA continues to
seek new information on field methods
to measure and monitor contamination
and its effects on the environment.
35
-------
Future Directions And Challenges
Is the Superfund program
working? Yes. This complex and
challenging program is now up and
running.
During the last 10 years, EPA
has developed a program which has
brought this country to a new level
of understanding about hazardous
substances and how they can be
treated. The Superfund program is
comprehensive, yet flexible and
innovative. Its mission is both
immediate and long-range; its focus
is specific enough to handle individ-
ual site cleanups with precision, yet
broad enough to encourage advances
in a relatively new scientific and
technical field.
Superfund has resulted in
permanent solutions to major
hazardous waste problems already.
But that is not enough. After 10
years of experience, the most
important lesson that all Superfund
participants have learned is that the
program faces a workload stretching
well into the next century. The
hazardous waste problem in the
United States remains large, com-
plex, and long-term. The job ahead
is enormous. It will take technical
innovation and competence, man-
agement skill and creativity, and
old-fashioned dedication and hard
work to clean all the sites currently
known to present unacceptable risk.
And that number is growing, as new
sites continue to be discovered.
The Agency is looking beyond
the next 10 years to project a pro-
gram for the future—Superfund
2000. Superfund 2000 is a concept
for long-term program planning.
As part of this concept, EPA is
programs, are being assessed. In
keeping with the Agency-wide goal
of increasing multi-media enforce-
ment efforts by 25 percent, EPA is
examining the future role of respon-
sible parties and State and local
governments in the Superfund
program. All these studies and
activities will help ensure that an
integrated, pragmatic, and results-
oriented Superfund program will
continue to evolve.
The hazardous waste problem in the United States
remains large, complex, and long-term.
conducting studies of the possible
universe of sites to be cleaned up by
Superfund or other parties. An
outyear liability model will help the
Superfund program estimate pos-
sible future cleanup costs under
different scenarios. The Agency
also is looking at past remedy
selection decisions and evaluating
patterns that may indicate the future
success of various technologies.
Opportunities for greater program
integration, particularly between the
Superfund and Resource Conserva-
tion and Recovery Act (RCRA)
The Agency is proud of its hard-
won accomplishments in the Super-
fund program, and will continue to
use new management and techno-
logical approaches to accelerate the
pace of cleanup, expand its effi-
ciency and activity, improve the
quality of the program over time,
and build public confidence. There
are no miracle cures for the hazard-
ous waste problem. But EPA has a
clear and cogent strategy for meet-
ing this challenge beyond this
century and into the next millen-
nium.
36
-------
EPA
Superfund
Offices
U.S. Environmental Protection Agency
Office of Emergency & Remedial Response
401 M Street, SW
Washington, D.C. 20460
CML (Commercial): (202)382-2090
FTS (Federal Telecommunications
System): 382-7883
EPA Region 1
Waste Management Division
JFK Federal Building
Boston, Massachusetts 02203
CML: (617)565-3715
FTS: 835-3715
EPA Region 2
Emergency & Remedial Response Division
Jacob K. Javitz Federal Building
26 Federal Plaza
New York, New York 10278
CML: (212)264-2657
FTS: 264-2657
EPA Region 3
Hazardous Waste Management Division
841 Chestnut Building
Philadelphia, Pennsylvania 19107
CML: (215)597-9800
FTS: 597-9800
EPA Region 4
Waste Management Division
345 Courtland Street, NE
Atlanta, Georgia 30365
CML: (404)347-4727
FTS: 257-4727
,0
EPA Region 5
Waste Management Division
230 South Dearborn Street
Chicago, Illinois 60604
CML: (312)353-2000
FTS: 353-2000
EPA Region 6
Hazardous Waste Management Division
First Interstate Bank Tower at Fountain Place
1445 Ross Avenue, 12th Floor, Suite 1200
Dallas, Texas 75202
CML: (214)655-6444
FTS: 255-6444
EPA Region 7
Waste Management Division
726 Minnesota Avenue
Kansas City, Kansas 66101
CML: (913)551-7000
FTS: 276-7003
EPA Region 8
Hazardous Waste Management Division
999 18th Street, Suite 500
Denver, Colorado 80202-2405
CML: (303)293-1603
FTS: 330-1603
EPA Region 9
Hazardous Waste Management Division
75 Hawthorne Street
San Francisco, California 94105
CML: (415) 744-1500
FTS: 484-1020
EPA Region 10
Hazardous Waste Division
1200 Sixth Avenue
Seattle, Washington 98101
CML: (206)442-1200
FTS: 399-1200
-------
For More Information
Dockets
Maintain the official rulemaking files, which include
official statements of the Administrator's position,
transcripts of hearings, litigation records, and public
comments.
RCRA Docket And Information Center: Contains
rulemaking files, publications, and background docu-
ments concerning the Resource Conservation and
Recovery Act.
(202) 475-9327
Superfund Docket: Provides rulemaking files, back-
ground documents, and viewing copies of Records of
Decision concerning the Comprehensive Environmental
Response, Compensation, and Liability Act.
(202) 382-3046
Superfund Documents Center: Manages all aspects of
document production, distribution, archiving, and
maintenance of bibliography. Ensures that the bibliogra-
phy is available to the public through the National
Technical Information Service (NTIS) and provides
document inventory service to agency staffs. Write
Superfund Documents Center - OS-240.
Public Information Center: Maintains a broad spec-
trum of EPA program publications of general environ-
mental interest, available to the public upon request.
Public Information Center
U.S.EPA(PM-211B)
401 M Street, SW
Washington, DC 20460
(202) 382-2080 or 475-7751
Hotlines
Provide information to the public and the regulated
community in interpreting regulations and policies.
RCRA/CERCLA: Responds to questions from the
public and the regulated community on the Resource
Conservation and Recovery Act, and the Comprehensive
Environmental Response, Compensation, and Liability
Act (Superfund). Hours of operation are Monday
through Friday, 8:30 a.m. to 7:30 p.m. Eastern Time.
(800) 424-9346
(703) 920-9810 in the Washington, DC area
(800) 553-7672 TDD
Emergency Planning And Community Right-To-
Know: Provides communities and individuals with help
in preparing for accidental releases of toxic chemicals.
This hotline is maintained as an information resource
rather than an emergency number, and serves to comple-
ment the RCRA/CERCLA Hotline.
(800) 535-0202
Libraries
The EPA Headquarters library maintains a variety of
reference materials, data bases, and both general and
special collections on environmental topics, including
hazardous waste.
Headquarters Library
EPA, Room M2904
401 M Street, SW
Washington, DC 20460
(202) 382-5921
In addition to the Headquarters library, there is a library
in each of EPA's ten Regional Offices (the addresses
appear on the "EPA Superfund Offices" page and the
telephone numbers are listed on the next page).
National Response Center (NRC)
Operated by the U.S. Coast Guard, this emergency
hotline is used to report spills of oil and other hazardous
materials. Calls are accepted 24 hours a day, every day
of the year.
(800) 424-8802
(202) 426-2675 in the Washington, DC area
Hazardous Waste Ombudsman
Assists citizens and the regulated community who have
had problems voicing a complaint or getting an issue
resolved about hazardous waste. There is a Hazardous
Waste Ombudsman at EPA Headquarters and one in each
of EPA's ten Regional Offices (addresses on page 37).
(703) 557-1938
Center For Environmental Research
Information (CERI)
Serves as a central point of distribution for EPA research
results and reports. Also conducts workshops and
seminars on environmental regulations, new technolo-
gies, and the health effects of environmental chemicals.
The Center plays a major role in Superfund research,
development, and response.
CERI
U.S. Environmental Protection Agency
Cincinnati, OH 45268
(513) 569-7391
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For More Information
For information on training for and response to hazard-
ous materials emergencies, contact the Technical Support
Division at (513) 569-7562.
National Technical Information
Service (NTIS)
A self supporting agency of the U.S. Department of
Commerce, NTIS serves as a repository for more than
1.6 million technical reports, summarizing government,
university, and corporate research worldwide. In addi-
tion to providing public access to the entire Superfund
bibliography, NTIS also maintains Superfund computer
datafiles, providing up-to-date information including the
names and locations of potential hazardous waste sites
reported to EPA.
U.S. Department of Commerce
NTIS
5285 Port Royal Road
Springfield, VA 22161
(703)487-4650
Regional Offices
EPA has ten Regional Offices to provide the public with
both general and technical information about specific
environmental issues in the States they oversee.
EPA Region 1:
EPA Region 2:
EPA Region 3:
EPA Region 4:
Connecticut, Massachusetts,
Maine, Vermont, New Hampshire,
Rhode Island
General Number: (617)565-3715
Hazardous Waste Ombudsman:
(617) 565-3394
New Jersey, New York, Puerto Rico,
Virgin Islands
General Number: (212) 264-2657
Hazardous Waste Ombudsman:
(212)264-4711
Delaware, Maryland, Pennsylvania,
Virginia, West Virginia,
District of Columbia
General Number: (215) 597-9800
Hazardous Waste Ombudsman:
(215) 597-0982
Alabama, Florida, Georgia, Ken-
tucky, Mississippi, North Carolina,
South Carolina, Tennessee
General Number: (404) 347-4727
EPA Region 5:
EPA Region 6:
EPA Region 7:
EPA Region 8:
EPA Region 9:
EPA Region 10:
(800) 282-0239 in GA; (800) 241-
1754 in other Region 4 States
Hazardous Waste Ombudsman:
(404) 347-3004
Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin
General Number: (312) 353-2000
(800) 572-2515 in IL; (800) 621-
8431 in other Region 5 States
Hazardous Waste Ombudsman:
(312) 353-5821
Arkansas, Louisiana, New Mexico,
Oklahoma, Texas
General Number: (214) 655-6444
Environmental Emergency Hotline -
24 hours: (214)655-2222
Hazardous Waste Ombudsman:
(214) 655-6765
Iowa, Kansas, Missouri, Nebraska
General Number: (913)551-7000
Hazardous Waste Ombudsman:
(913) 551-7051
Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming
General Number: (303) 293-1603;
(800) 759-4372
Hazardous Waste Ombudsman:
(303)294-1111
Arizona, California, Hawaii,
Nevada, American Samoa, Guam,
Commonwealth of the Northern
Mariana Islands, Republic of Palau,
Federated States of Micronesia, the
Republic of the Marshall Islands
General Number: (415) 744-1500
RCRA Hotline: (415) 744-2074
Superfund Hotline: (800)231-3075
Hazardous Waste Ombudsman:
(415) 744-1470
Alaska, Idaho, Oregon, Washington
General Number: (206)442-1200
Hazardous Waste Ombudsman:
(206) 442-2871
39
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Glossary of Terms
Administrative Order on Consent (AOC): An admin-
istrative legal agreement between EPA and potentially
responsible parties (PRPs) whereby PRPs agree to
perform or pay the cost of a site response action. The
agreement describes actions to be taken at a site and may
be subject to a public comment period. Unlike a consent
decree, an AOC does not have to be approved by a judge.
Administrative Record: A file that contains all infor-
mation used by the lead agency to make its decision on
the selection of a response action under CERCLA. This
file is available for public review and a copy is estab-
lished at or near the site, usually at one of the informa-
tion repositories. Also, a duplicate file is held in a
central location, such as a Regional or State office.
Affected Public: The people who live and/or work near
hazardous waste sites.
Agency for Toxic Substances and Disease Registry
(ATSDR): A Federal agency within the Department of
Health and Human Services which, in conjunction with
EPA, is responsible for implementing health-related
authorities of CERCLA, including conducting site-
specific health assessments.
Alternative Remedial Contract Strategy (ARCS)
Contractors: Government contractors who provide
project management and technical services to support
remedial response activities at National Priorities List
sites.
Applicable or Relevant and Appropriate Require-
ments (ARARs): ARARs include any State or Federal
statute or regulation that pertains to protection of human
health and the environment in addressing certain site
conditions or using a particular cleanup technology at a
Superfund site. A State law to preserve wetland areas is
an example of an ARAR. EPA must consider whether a
remedial alternative meets ARARs as part of the process
for selecting a cleanup alternative for a Superfund site.
Availability Session: An informal meeting in a public
location where interested citizens can talk with EPA and
State officials on a one-to-one basis.
Bench-Scale Tests: Laboratory testing of potential
cleanup technologies (also known as treatability studies).
Bioremediation: The use of living organisms, such as
bacteria and fungi, to treat hazardous substances.
Brine Mud: A waste material, often associated with
well drilling or mining, composed of mineral salts and
other inorganic compounds.
Cap: A layer of clay or other highly impermeable
material installed over the top of a closed landfill to
prevent entry of rainwater and minimize leakage.
Carbon Tetrachloride: A colorless liquid used in
refrigerants, metal degreasers, agricultural fumigants,
and as a dry-cleaning agent. Exposure to it can cause
damage to the central nervous system, liver, and kidneys.
Clean Water Act: Federal law regulating the discharge
of pollutants into surface waters.
Cleanup: Actions taken to deal with a release or threat-
ened release of hazardous substances to protect human
health and/or the environment.
Community Relations: EPA's program to inform and
involve the public in the Superfund process and respond
to community concerns.
Community Relations Coordinator (CRC): The EPA
official responsible for overseeing and directing commu-
nity relations activities.
Community Relations Plan (CRP): The document that
outlines specific community relations activities that
occur during a remedial response at a site. The CRP
outlines how EPA will keep the public informed of work
at the site and the ways in which citizens can review and
comment on decisions that may affect the final actions at
the site.
Comprehensive Environmental Response, Compensa-
tion, and Liability Act (CERCLA): A Federal law
passed in 1980 and amended in 1986 by the Superfund
Amendments and Reauthorization Act. CERCLA
created a special tax that goes into a Trust Fund, com-
monly known as Superfund, to investigate and clean up
abandoned or uncontrolled hazardous waste sites. Under
the program, EPA can either:
• Perform site cleanup when parties responsible
for the contamination cannot be located or are
unwilling or unable to perform the work; or
• Take legal action to force parties responsible for
site contamination to clean up the site or pay
back the Federal government for the cost of the
cleanup.
40
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Glossary of Terms
Comprehensive Environmental Response, Compensa-
tion, and Liability Information System (CERCLIS):
The official information system for the Superfund
program, it contains site-specific and general program
data, such as site location, technical cleanup process,
scheduled activities, and costs to date.
Consent Decree: A legal document, approved and
issued by a State or Federal district court, that formalizes
an agreement between a State or EPA and potentially
responsible parties (PRPs) whereby PRPs will perform
all or part of a Superfund site cleanup. The consent
decree describes actions that PRPs are required to
perform and is subject to a public comment period.
Cooperative Agreement (CA): An assistance agree-
ment whereby EPA transfers money, property, services,
or anything of value to a State for the accomplishment of
certain activities or tasks as authorized by CERCLA.
Core Program Cooperative Agreement (CPCA): An
assistance agreement whereby EPA provides support
funds to States and Indian Tribes to help defray the cost
of non-site-specific activities, such as administrative and
clerical salaries, computer resources, and training.
Cost Recovery: A legal process through which poten-
tially responsible parties can be required to pay back the
Federal government for money it spends on any cleanup
actions.
Covenant Not to Sue: A written agreement that releases
settling potentially responsible parties from present or
future liability.
De Minimis Settlements: Settlements that are smaller
agreements separate from the larger settlement for the
chosen cleanup remedy. .Under de minimis settlements,
contributors of a relatively small amount of waste to a
site, or landowners who bought the site but did not
contribute wastes to it, may resolve their liability.
Department of Defense (DOD): The U.S. Army Corps
of Engineers within DOD has specialized equipment and
personnel available to assist in removal actions. The
Corps serves as EPA's primary agent for Federal-lead
remedial designs and remedial actions.
Department of Energy (DOE): DOE provides special
assistance when radioactive substances are involved at
Superfund sites.
Department of Justice (DOJ): DOT assists EPA in
enforcement activities and legally represents EPA when
cases go to court.
Emergency Preparedness and Community Right-to-
Know Act (EPCRA): A Federal law that established a
four-part program to define an emergency planning
structure at the State and local levels; require emergency
notification of hazardous chemical releases; require
notification of chemical use, storage, or production
activities; and define annual emissions reporting require-
ments.
Enforcement: EPA's efforts, through legal action if
necessary, to force potentially responsible parties to
respond to information requests or perform or pay for a
Superfund site cleanup.
Fact Sheet: A document prepared and distributed by
EPA to inform the public of Superfund site or program
activities.
Feasibility Study (FS): See Remedial Investigation/
Feasibility Study.
Future Liability: Refers to potentially responsible
parties' obligations to pay for additional response
activities beyond those specified in the Record of Deci-
sion or consent decree.
Gas Chromatograph/Mass Spectrometer: A highly
sophisticated instrument that identifies the molecular
composition and concentrations of the various chemicals
in water and soil samples.
General Notice Letter: A letter, issued by EPA, advis-
ing potentially responsible parties of their potential
liability at a Superfund site.
Ground Water: Water found beneath the earth's
surface that fills pores between materials such as sand,
soil, or gravel. Ground water can occur in sufficient
quantities that it can be used for drinking water, irriga-
tion, and other purposes.
Hazard Ranking System (HRS): A scoring system
used to evaluate potential relative risks to human health
and the environment from releases or threatened releases
of hazardous substances. EPA and States use the HRS to
calculate a site score, from 0 to 100, based on the actual
or potential release of hazardous substances from a site
through air, surface water, or ground water .
41
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Glossary of Terms
Hazardous Substance: Any material that poses a threat
to human health and/or the environment. Typical
hazardous substances are materials that are toxic, corro-
sive, ignitable, explosive, or chemically reactive.
Hazardous Waste: By-products or wastes that are toxic,
corrosive, ignitable, explosive, or chemically reactive.
Although the legal definition of hazardous waste is
complex, the term more generally refers to any waste that
EPA believes could pose a threat to human health and the
environment if improperly treated, stored, transported, or
disposed.
Health Assessment: A study, required by CERCLA and
performed by the Agency for Toxic Substances and
Disease Registry (ATSDR), that determines the potential
risks to human health posed by a site.
In-situ Stripping: A treatment system that removes or
"strips" volatile organic compounds from contaminated
ground water or surface water by forcing an airstream
through the water and causing the compounds to evapo-
rate.
Information Exchange: A phase that occurs early in the
negotiation process through which EPA and potentially
responsible parties exchange information and knowledge
about past activities at a Superfund site.
Information Repository: A file containing current
information, technical reports, and reference documents
regarding a Superfund site. The information repository is
usually located in a public building that is convenient for
local residents, such as a public school, library, or city
hall.
Innovative Technologies: New or inventive methods to
treat effectively hazardous waste and reduce risks to
human health and the environment.
Inorganic Compounds: Compounds composed of
mineral materials, including elemental salts and metals
such as iron, aluminum, mercury, and zinc.
Local Governments Reimbursement (LGR) Program:
An EPA program that provides up to $25,000 directly to
local governments to help ease the financial burden of
conducting temporary emergency measures in response
to a hazardous substance threat.
Long-Term Contracting Strategy: Refers to EPA's
efforts to analyze the long-term contracting needs of the
Superfund program and design or realign contracts to
meet those needs.
Management Review of the Superfund Program (90-
Day Study): An EPA report, commissioned by the EPA
Administrator and published in May 1989, that provides
an assessment of the Superfund program and suggests a
practical strategy for realizing the greatest environmental
benefit possible, given the long-term, incremental nature
of Superfund.
Media: Components of the environment, including
surface water, ground water, soil, and air, which are the
subject of regulatory concern and activities.
Mercury: A silver, liquid metal that is highly toxic and
can be absorbed through the skin. It is used in ther-
mometers, batteries, fluorescent light bulbs, pharmaceuti-
cals, and many other products.
Metals: Compounds such as chromium and lead that can
be toxic at relatively low concentrations.
Mixed Funding: Settlements in which potentially
responsible parties and EPA share the costs of the
response action.
Monitoring Wells: Special wells drilled at specific
locations on or off a hazardous waste site where ground
water can be sampled at selected depths and studied to
determine such things as the direction of ground water
flow and the types and amounts of contaminants present.
Moratorium: During the negotiation process, a period
of 60 or 90 days during which EPA and potentially
responsible parties may reach settlement but no site
response activities can be conducted.
National Oil and Hazardous Substances Pollution
Contingency Plan (NCP): The Federal regulation that
provides a blueprint for Superfund program operations.
National Priorities List (NPL): EPA's list of the most
serious uncontrolled or abandoned hazardous waste sites
identified for possible long-term remedial response using
money from the Trust Fund. The list is based primarily
on the score a site receives from the Hazard Ranking
System. EPA is required to update the NPL at least once
a year.
42
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Glossary of Terms
National Response Center (NRC): The center operated
by the U.S. Coast Guard that receives and evaluates
reports of oil and hazardous substance releases into the
environment and notifies the appropriate agency(ies).
The NRC can be contacted 24 hours a day, toll-free at
800-424-8802. T
National Response Team (NRT): Representatives of
14 Federal agencies that coordinate Federal responses to
nationally significant pollution incidents and provide
advice and technical assistance to the responding
agency(ies).
Negotiations: After potentially responsible parties
(PRPs) are identified for a site, EPA coordinates with
them to reach a settlement. Negotiated settlements result
in PRPs paying for or conducting cleanup activities
under EPA supervision. If negotiations fail, EPA can
order the PRPs to conduct the cleanup or EPA can pay
for the cleanup using Superfund monies and then sue the
PRPs to recover costs.
No Further Remedial Action Planned (NFRAP): A
determination made by EPA following a preliminary
assessment that a site does not pose a significant risk and
so requires no further activity under CERCLA.
Non-Binding Allocations of Responsibility (NEAR):
Process for EPA to propose a way for potentially respon-
sible parties to allocate costs among themselves.
Non-compliance: If a potentially responsible party
(PRP) does not meet the agreement set forth in a negoti-
ated settlement, the PRP is in "non-compliance" and
EPA can invoke penalties, usually in the form of fines.
On-Scene Coordinator (OSC): The Federal official
who coordinates and directs Superfund removal actions.
Operable Unit (OU): An action taken as one part of an
overall site cleanup. For example, a carbon absorption
system could be installed to halt rapidly spreading
ground water contaminants while a more comprehensive
and long-term remedial investigation/feasibility study is
underway. A number of OUs can be used in the course
of site cleanup.
Operation & Maintenance (O&M): Activities con-
ducted at a site after a response action has concluded, to
ensure that the cleanup or containment system is func-
tioning properly.
Organic Compounds: Chemical compounds composed
of carbon and hydrogen, including materials such as oils,
pesticides, and solvents.
Pilot Tests: Testing of a cleanup technology, performed
under actual site conditions, to identify potential prob-
lems prior to full-scale implementation.
Political Subdivision: The definition of political
subdivision varies from State to State, so each State
determines what units of government meet its legislative
definition. A political subdivision can participate in
Superfund cleanup as a lead or support agency when
EPA and the State agree that this enhances the cleanup
process and results in an efficient, economical, and well-
coordinated use of resources.
Poly chlorinated Biphenyls (PCBs): A family of
organic compounds used since 1926 in electric trans-
formers as insulators and coolants, in lubricants, carbon-
less copy paper, adhesives, and caulking compounds.
PCBs do not break down into new and less harmful
chemicals and are stored in the fatty tissues of humans
and animals. EPA banned the use of PCBs in 1979.
Potentially Responsible Party (PRP): An individual(s)
or company(ies) (such as owners, operators, transporters,
or generators) potentially responsible for, or contributing
to, the contamination problems at a Superfund site.
Whenever possible, EPA requires PRPs, through admin-
istrative and legal actions, to clean up hazardous waste
sites they have contaminated.
Potentially Responsible Party (PRP) Search: An
investigation, conducted by a State or EPA, into the
parties who may be liable for the cleanup at a site. The
PRP search enhances EPA's success in negotiating with
PRPs to conduct a response action under EPA's supervi-
sion.
Preliminary Assessment (PA): The process of collect-
ing and reviewing available information about a known
or suspected hazardous waste site or release. EPA or
States use this information to determine if the site
requires further study. If further study is needed, a site
inspection is undertaken.
Present Liability: Refers to a potentially responsible
party's obligation to pay response costs already incurred
by the government and to complete remedial activities
set forth in the Record of Decision or consent decree.
43
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Glossary of Terms
Proposed Plan: A plan for site cleanup that is available
to the public for comment. It highlights key aspects of
the remedial investigation/feasibility study report,
provides a brief analysis of remedial alternatives under
consideration, identifies the preferred alternative, and
provides members of the public with information on how
they can participate in the remedy selection process.
Public Comment Period: A time period during which
the public can review and comment on various docu-
ments and EPA actions. For example, a comment period
is provided when EPA proposes to add sites to the
National Priorities List. Also, a minimum 30-day
comment period is held to allow community members to
review and comment on a draft feasibility study and
Proposed Plan.
Record of Decision (ROD): A public document that
explains which cleanup altemative(s) will be used at a
National Priorities List site. The ROD is based on
information and technical analysis generated during the
remedial investigation/feasibility study and consideration
of public comments and community concerns.
Records of Decision System (RODS): A detailed data
base of ROD information used to promote national
consistency of remedies chosen at similar sites.
Remedial Action (RA): The actual construction or
implementation phase that follows the remedial design of
the selected cleanup alternative at a site on the National
Priorities List.
Remedial Design (RD): An engineering phase that
follows the Record of Decision when technical drawings
and specifications are developed for the subsequent
remedial action at a site on the National Priorities List.
Remedial Investigation/Feasibility Study (RI/FS):
Investigative and analytical studies usually performed at
the same time in an interactive process, and together
referred to as the RI/FS. They are intended to:
• Gather the data necessary to determine the type
and extent of contamination at a Superfund site;
• Establish criteria for cleaning up the site;
• Identify and screen cleanup alternatives for
remedial action; and
• Analyze in detail the technology and costs of the
alternatives.
Remedial Project Manager (RPM): The EPA or State
official responsible for overseeing remedial response
activities.
Removal Action: A fast track action taken over the
short-term to control immediate threats to people and/or
the environment from a release or threatened release of
hazardous substances.
Removal Site Evaluation (RSE): A document that
determines if a removal action is necessary; the evalu-
ation is composed of the preliminary assessment and the
site inspection.
Reportable Quantities (RQs): The quantity of a
hazardous substance that, if released into the environ-
ment, may present substantial danger to the human health
or welfare or the environment and must be reported to
the National Response Center or EPA.
Responsiveness Summary: A summary of oral and/or
written public comments received by EPA during a
comment period on key EPA documents, and EPA's
responses to those comments. The responsiveness
summary is a key part of the Record of Decision, high-
lighting community concerns for EPA decisionmakers.
Revised Hazard Ranking System (rHRS): Modifica-
tions to the HRS, as required by the Superfund Amend-
ments and Reauthorization Act, that became effective
March 15, 1991.
Risk Assessment: An evaluation performed as part of
the remedial investigation to assess conditions at a
Superfund site and determine the risk posed to human
health and the environment.
Risk Reduction: EPA's efforts to reduce, control, or
eliminate human health, welfare, and ecological risks
posed by environmental problems.
Site Assessment Program: A means of evaluating
hazardous waste sites, through preliminary assessments
and site inspections, to develop a Hazard Ranking
System score that is used to determine if a site should be
placed on the National Priorities List.
Site Inspection (SI): A technical phase that follows a
preliminary assessment designed to collect more exten-
sive information on a hazardous waste site. The informa-
tion is used to score the site with the Hazard Ranking
System to determine whether a remedial action is needed.
44
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Glossary of Terms
Site Safety Plan: A crucial element of all removal
actions and the remedial design/remedial action phase of
remedial actions, it includes information on equipment
being used, precautions to be taken, and steps to take in
the event of an emergency situation at the site.
Sludge: A generic term that describes a thickened semi-
solid waste byproduct of an industrial or recycling
process.
Special Notice Letter: A letter, sent by EPA, that
initiates the process of formal enforcement negotiations,
and invokes a negotiation moratorium between PRPs and
EPA.
Strict, Joint and Several Liability: Strict liability
means that the Federal government can hold a potentially
responsible party (PRP) liable without showing that the
PRP was at fault. Joint and several liability means that
any one PRP can be held liable for the entire costs of site
cleanup, regardless of the share of waste contributed by
that PRP.
Superfund Amendments and Reauthorization Act
(SARA): Modifications to CERCLA enacted on October
17, 1986.
Superfund Innovative Technology Evaluation (SITE):
An EPA program designed to promote the development
and use of innovative treatment technologies to clean up
Superfund sites.
Superfund Memorandum of Agreement (SMOA): An
optional agreement that specifies the procedures that
EPA and a State or Indian Tribe will use to implement
CERCLA and the National Oil and Hazardous Sub-
stances Contingency Plan (NCP). These procedures then
serve as the basis for site-specific Cooperative Agree-
ments or Superfund State Contracts.
Superfund State Contract (SSC): A contract between
EPA and a State that is legally binding on both parties.
The SSC is used to document EPA and State responsi-
bilities and to obtain any necessary State assurances for
response actions.
Superfund: The common name used for the Compre-
hensive Environmental, Response, Compensation, and
Liability Act. Also referred to as the Trust Fund.
Technical Assistance Grant (TAG) Program: A
program that provides grants of up to $50,000 per
Superfund site so citizens can hire independent technical
advisors to help them understand information related to
cleaning up a site.
Thermal Treatment: The use of elevated temperatures
to treat hazardous waste by changing the chemical and/or
physical composition of the waste.
Total Quality Management (TQM): The application of
management techniques and statistical controls to a
process in order to improve any product "constantly and
forever."
Toxicological Profile: An examination, summary, and
interpretation of a hazardous substance to determine
levels of exposure and associated health effects.
Treatability Studies: Tests of potential cleanup tech-
nologies conducted in a laboratory (also known as bench-
scale tests).
Treble Damages: CERCLA provides that EPA can sue
potentially responsible parties (PRPs) for up to three
times the cost of cleanup, if the PRPs consistently do not
comply with a negotiated settlement.
Unilateral Administrative Order (UAO): An adminis-
trative legal document issued unilaterally by EPA
directing a potentially responsible party to perform site
cleanup. UAOs are typically issued when negotiations
between PRPs and EPA have broken off. It sets forth the
liability of the party for the cleanup, describes actions to
be taken, and subjects the recipient to penalties and
damages for noncompliance. Unilateral orders may be
enforced in court through judicial action.
U.S. Coast Guard (USCG): The USCG is responsible
for managing responses to oil spills and other hazardous
releases in coastal waters and inland waterways. The
USCG operates the National Response Center.
Volatile Organic Compounds: Carbon-containing
chemical compounds that evaporate (volatilize) readily at
room temperature.
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