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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


     Even  before   the  enactment   of   SARA,   EPA  began   planning  for  its
implementation.  Several workgroups were formed late in fiscal year 1986 to begin
the analysis required  to implement the  anticipated major amendments to CERCLA.
The most significant efforts  focused on the required revisions to the National
Contingency Plan (NCP)  and  the  Hazard Ranking System (MRS) methodology,  and on
the development of regulations to implement the Technical Assistance  Grant (TAG)
provision.  The TAG interim final  regulation was published on March  23, 1988.

     On October 24, 1986, one week after SARA was passed, EPA issued a "date of
enactment" memorandum  that provided guidance on how to make the transition from
operating  procedures  under the  old law to  procedures that would address  the
priorities and achieve the objectives  under  CERCLA,  as amended.   The highest
priority was initiating construction projects  at sites already in the remedial
pipeline.  On December 24,  1986,  the Assistant Administrator  for Solid Waste and
Emergency Response  (OSWER)  issued important interim guidance on criteria to be
used in selecting Superfund remedies.

     Another  early initiative  involved  EPA's  participation  in  drafting  the
Executive  Order   that  transferred  the   authority   and   responsibility  for
implementing  CERCLA from  the  President  to  EPA  and  other Executive  Branch
organizations.  The President signed Executive Order 12580 on January 23, 1987,
following months of work by staff  at EPA,  the Office  of Management and Budget
(OMB),  the  National Response Team, and other  agencies.   After  receiving  its
responsibilities from the President, EPA developed internal  policy  documents that
redelegated the Administrator's responsibilities to Regional Administrators (RAs)
and Assistant Administrators  (AAs).

     On February 26, 1987, the Administrator, Lee M.  Thomas, signed EPA's interim
delegations of authority, which made implementation of new Superfund provisions
possible, pending final resolution of how authority and responsibility would be
allocated within the Agency.   On  September 13 and  21,  1987,  the Administrator
signed  the last  two of a series of decision memoranda,  completing most  of the
internal delegations assigning EPA's CERCLA responsibilities.

     As a result of early efforts, EPA  met CERCLA's deadlines for revising the
reportable quantity (RQ) regulations and initiated several other RQ rulemakings.
EPA prepared  a Report  to  Congress  required by  SARA on the  transportation of
hazardous  materials,    and  published  an   important   interim  final  rule  on
Reimbursement to Local Governments  on October 21, 1987.

     Implementing  the  CERCLA-mandated  revisions  to the NCP  has been a  major
effort for the past year,  involving a broad and comprehensive rulemaking process
to revise as well as restructure the document.  All  existing subparts of the NCP
will be revised, (some  will be  consolidated),  and  several  new subparts will be
added.  The principal  revisions  apply to the  removal  program and the selection
of remedy process.  In addition,  other  regulations  that  are  major in their own
right are part  of the NCP revisions now underway,  including State involvement and
Administrative Record  regulations.   The  revised NCP was proposed in December 1988
(53 FR 51394).

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     Another key initiative was to  issue interim guidance  for  implementing those
Superfund provisions that became effective with the passage of SARA and were not
dependent upon promulgation of regulations.  During the year,  EPA issued 10 such
interim guidance documents.  As part of the CERCLA enforcement program,  several
policy  and  guidance  documents  were  developed,  some  in  response   to  CERCLA
provisions,  to  further the  program's  goals.   Those  that have been finalized
include Streamlining the  Settlement  Process  (February 12, 1987)  and Nonbinding
Allocations  of  Responsibility (NBARs) (May  28,  1987); interim  guidance on  de
minimis settlements  was  issued on June 19,  1987.

     On March 5,  1987, EPA held a national  teleconference designed to communicate
CERCLA's provisions to  a  broad range of EPA Regional  and State  program staff.
After the teleconference,  six 2-day conferences were held to describe and discuss
the  implementation issues  and  policies  with  EPA  staff  from the 10 Regional
offices and with State program staff.  Also,  throughout the year,  EPA conducted
a variety of outreach and training activities  designed to assist EPA Regional and
State staff.  Headquarters' program staff and Regional staff coordinated visits
to  all EPA  Regions to provide hands-on assistance  in  developing RODs  and
incorporating CERCLA requirements into projects in progress.

     With support from EPA,  the Agency  for Toxic Substances and Disease Registry
(ATSDR) conducted  106  health assessments, published  procedures  for  requesting
health assessments, and issued a manual on conducting health assessments.  Of the
106 health assessments  conducted, 60 were at National Priorities List  (NPL) sites
in 28 States, and 45 were at non-NPL sites in 21  States.   One health assessment
was  conducted in  response  to  a  public  petition.    In  addition,  ATSDR  also
completed 1,467 health consultations  in 50  States, the District of Columbia, and
several territories and foreign countries and awarded 11  cooperative agreements
to States, enabling them  to develop  the capability to perform their  own health
assessments.  ATSDR did not issue any health advisories in FY87.

     Existing technical support programs were continued and several new research
programs were begun to satisfy the  need to better assess  the health risks posed
by  hazardous substances  and to develop  treatment  technologies  that  provide
permanent protection of human health and the environment.   In response to the
mandate for technology development, EPA carried out research in several areas in
addition to the Superfund Innovative  Technology Evaluation (SITE) program.  This
research included:   treatment technology evaluation,  which addressed four major
treatment processes and continued research on ground-water cleanup alternatives;
personnel protection research directed toward safety concerns, such as safety
procedures and protective  clothing and equipment;  and a university research grant
program to conduct  applied research on  measurement and monitoring methods and on
in situ treatment of hazardous waste.

     In response to CERCLA-authorized  health-related  research, EPA,  ATSDR,  and
the National  Institute  for Environmental  Health Sciences  (NIEHS) agreed on an
integrated research effort  in which each agency will  focus on specific research
areas.  EPA  will concentrate  on risk assessment  techniques,  toxicological test
methods, and exposure assessment methodology.   ATSDR1s research will be related
to CERCLA-mandated health assessments, and NIEHS  will support multidisciplinary
biomedical research through university grants.

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
     The EPA Office  of  Research and Development (ORD) also provided a range of
technical assistance during the year.  Endangerment assessments  of  20 sites were
conducted and a risk assessment review group was established.  Chemical toxicity
profiles were  prepared  for 74 chemicals; RQ  documentation was  prepared for 50
suspected carcinogens,  along with  draft documentation for 191  others;  and 12
rapid response assessments  of specific chemicals were made.  ORD also provided
engineering assistance  to  Regional  offices  for 35 sites and monitoring support
to Regional offices and  the National Enforcement Investigations Center (NEIC) for
400 sites.

     Because of  the potential  for  adverse  ambient air  impacts from Superfund
site emissions, the Office of Air Quality Planning and Standards  (OAQPS) and the
Regional Air Program Offices  were given increased responsibility and resources
to  provide  technical  assistance to  the Superfund  program in  evaluating air
impacts and to advise the Superfund Regional  offices  on appropriate removal and
remedial  actions  for  Superfund  sites  where air  issues   are of concern.   An
Air/Superfund  Coordinator  has  been  designated  at   Headquarters  and  in each
Regional Air  Office to  facilitate  coordination between the  Air and Superfund
programs.

     The cost  recovery  program  focused on projecting cost recovery revenue for
the next 5 years  and on prioritizing sites  for cost recovery based on statutes
of limitations and availability of potentially  responsible parties (PRPs).  EPA
Regional offices referred 37 sites with a combined dollar value of approximately
$30,500,000 to Headquarters for cost recovery action.  The Agency completed 62
cost recovery settlements,  including settlements that did not require litigation,
with a total reimbursement to the Trust  Fund  of $18,866,000.

Removal Program Activities

     Removal actions are relatively  short-term actions designed to protect public
health, welfare,  or the environment.   Removal actions  may  be undertaken  in
response to an emergency, such as a fire, chemical leak, or explosion.   Removal
actions can be quite extensive, involving significant engineering and requiring
several million dollars  to complete.

     In a program with  a high  level  of success since it  began in fiscal year
1981,  by far the largest number of removals  was  conducted this year.  Using Fund
resources, 254 removal actions were begun during the year and 195 were completed.
Responsible parties  contributed an additional  50  removal  action starts  and 31
removal completions.  Also, the program reached a major milestone this year by
beginning action  on  its  1,000th removal, ending the  year  with a 7-year program
total of 1,057 Fund-financed removal action  starts.  The Agency also oversaw the
removal activities of responsible parties, States, and local governments at 422
sites.

     The  removal  program  reissued  four Regional  Emergency  Response  Cleanup
Services (ERGS) zone contracts, and awarded the following additional contracts:
two Technical Assistance Team  (TAT) contracts; four dioxin contracts; one cleanup
standards  8(a)  (minority)  contract;  two Regional ERCs, both  of which  are 8(a)

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


(minority) contracts; one site-specific cleanup contract; and two environmental
emergency response unit (EERU) contracts.  These contracts in combination provide
the  technical  assistance and cleanup  service  that  EPA needs  to  implement an
effective removal program.

     In addition, EPA began working to implement  the recommendations of the On-
Scene Coordinator (OSC) Management Support Task Force.  The  recommended changes
are  intended to  assist  the  OSCs  in meeting current administrative requirements
for  financial  management,  contract  management,  and  documentation  for cost
recovery.  Five Regions  established Administrative Support Units to implement the
recommendations,  and the remaining Regions will establish similar units in FY88.

Pre-Remedial Program  Activities

     Pre-remedial  activities  are   investigative  and  analytical  activities
undertaken to  evaluate  the  threat,  or  potential threat, to human health  or the
environment posed by conditions  at a site, and to  determine  the  need  for further
action and set priorities for that action.  The Agency  made  substantial progress
toward meeting the statutory goal of completing preliminary  assessments (PAs) by
January 1988 on  all  sites in  CERCLIS at the time CERCLA was amended.   PAs were
completed on more than 4,000 sites, and site inspections (Sis) on more than 1,340
sites.  Ninety-nine  sites (including 32 Federal facilities) were listed  as NPL
sites, and 64  sites  (including one Federal facility) were proposed for listing.
In  addition,  the pre-remedial program substantially  completed development of
Update 7  to the  NPL  in  FY87,  and,  on June 24, 1988,  (53 FR  23988) proposed 229
new  sites.

     The pre-remedial program also increased  the  level  of effort for conducting
a PA so that lead agencies can more  effectively identify sites  that require Sis.
Guidance is also  being developed  to direct more resources to SI activity at sites
most likely to be proposed  for the NPL.

     As required by  section 105 of CERCLA, a  major effort to revise  the HRS was
undertaken during the year  that would ensure,  "to the maximum extent feasible,"
that  the  HRS  accurately  assesses the  relative  risk  to human  health and the
environment  posed by  potential  NPL  sites.    Accordingly,  a  number  of  new
evaluation factors  are being added to  the HRS,  including  the  threat  that the
contamination  poses  to the  human food  chain and ambient air  quality, and the
effect of contamination of surface water used for human  consumption and for
recreational purposes.  Although the rule will not become effective in time to
meet  the  statutory  deadline  established  by  section  105(c)(l)   (October  1988),
revision to the HRS is on an accelerated schedule, and the final rule  is expected
in the second  half of fiscal 1989.

Remedial Program Activities

     Remedial  actions are generally undertaken at complex sites  and usually take
longer than removal  actions.  Considerable study  is required to  select the most
effective  cleanup action,  which may  cost millions  of dollars to implement.
Project accomplishments for the  remedial program were significant:    183 RI/FS
starts (123 "first start" RI/FSs and 60 subsequent RI/FSs);  75  RODs  (58 initial

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


RODs and 17 subsequent RODs) were signed; 94 remedial design '(ED) starts; 54 RA
starts;  8  RA completions;  and 5 sites  entered the  operation  and maintenance
phase.

     A  significant  number of  remedial  actions  were  initiated  or  completed by
PRPs.   Of  the 123 first-start  RI/FSs,  47  are being conducted by PRPs.   Twenty-
four of the 94  remedial  design starts were begun in  accordance  with consent
decrees.  At the end of the year,  several  additional consent decrees were in the
final stages of preparation.

     To  implement the  remedy  selection provisions of  CERCLA,  the Agency issued
three interim guidance documents:   Interim  Guidance  on Superfund  Selection of
Remedy  (December 24,  1986);  Interim Guidance on  Compliance  with Applicable or
Relevant and  Appropriate Requirements  (July 9, 1987);  and  Additional Interim
Guidance for FY87 Records of Decision  (July  24, 1987).

     In addition, throughout FY87 EPA continued  to draft guidance for conducting
remedial investigations and feasibility studies under CERCLA and for preparing
RODs and proposed plans.  Interim ROD guidance is  scheduled for release in FY88;
a final guidance document,  however, will not be issued until the revisions to the
NCP are completed.

     The decisionmaking process underlying the  selection of a  remedy for a given
site is a multi-step process.   Remedial alternatives analyzed  in the feasibility
study  are  developed  by  screening   the  universe of  potentially  applicable
technologies and process options. By using  information on  contaminant types and
concentrations and  onsite  characteristics from  the remedial  investigation site
characterization,   technologies  and  process  options  that  clearly  are  not
appropriate are  screened out.   Each  remaining alternative   is  evaluated  with
respect  to nine criteria  developed  to address the  statutory  requirements  of
CERCLA  section 121.   The criteria include such factors as overall protection of
human health  and the environment, long-term effectiveness and  permanence,  and
reduction of toxicity,  mobility,  or volume of contaminants.  Based on the results
of  the  evaluation,  the Regional  Administrator  or Assistant  Administrator,  in
consultation with appropriate  State  personnel,  selects  the remedy  for a site.
When the remedy has been selected, the ROD is prepared.

     There  were  75  RODs  signed  in  FY87,  involving  a  total of  119  remedial
components.   Thirty-two of these components will employ at  least  one  type  of
treatment  that will permanently  and  significantly reduce the volume,  toxicity,
or  mobility  of  the hazardous  substances,  pollutants, and contaminants  at  the
sites.   Thirty-five remedies  involve  containment components to  address  non-
residual waste.  Ground-water pump  and treatment  actions  are components  of 32
of  the  selected  remedies.   Finally,  thirteen remedies  provide  for alternative
water supplies,  and seven recommend no futher action.  (See section 2.3.8 of the
Report  for a more detailed explanation.)

     EPA has  taken  several steps toward creating  a full-scale  program for  the
development and  evaluation of permanent  technologies  (i.e.,  technologies  that
provide a permanent solution to contamination problems at a site) by initiating
the  SITE  program   and  implementing  one  of its  major components,  the  SITE

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


demonstration program  (DP).  Two solicitations for technologies for the DP have
been published -- the  first, in February 1986, and the second, in January 1987.
EPA is working with 11 technologies selected during 1986.   One demonstration was
completed and five more are planned.

     New  technologies  were  also  generated  by  EPA  activities  riot  directed
primarily  toward this  goal:    treatability  studies  done  as part  of  FSs  at
Superfund sites  were  undertaken to determine  the comparative effectiveness of
various remedies; the  Superfund  Technology Support  Project (STSP),  a technical
assistance program, was initiated  to encourage the use of new technologies; and
a worldwide survey of  treatment  technologies was conducted.  Also,  in response
to CERCLA's requirement to establish  a program for  a 5-year review of sites at
which hazardous  substances remain after  completion  of a  remedial  action,  EPA
developed a draft policy that is included  in the  proposed NCP.

     The remedial program  awarded  two  Field Investigation Team (FIT) contracts
to provide support for the pre-remedial program.   In  addition, EPA awarded three
contracts to minority business firms;  two  contracts to  perform remedial response
activities and one contract to provide  remedial response for a specific site.

Program Management Initiatives

     Two major  remedial project management support activities  were initiated
this year:

     (1)  The Alternative  Remedial Contracts  Strategy (ARCS).   ARCS
          will promote  the continuity  of  contractor  performance from
          RI/FS  through construction management  (or RA), increase the
          level of competition for  contract awards, and facilitate the
          delegation of contract management to the Regions.  Contract
          awards under this program in  the two pilot Regions began in
          December 1987,  and procurement  actions will begin  in the
          remaining Regions next year.

     (2)  The RI/FS Improvements Initiative.   This effort has several
          objectives:   (i)  to  contain project  planning  activities
          within a  3-month period after  project  initiation;  (ii) to
          ultimately reduce the  overall RI/FS process to an 18-month
          schedule; (iii) to reduce overall costs; and  (iv)  to improve
          the  technical  quality of RI/FSs.   A report issued to the
          Regions on July 23,  1987  discussed several  initiatives aimed
          at  improving performance  on RI/FS  projects  and proposed
          implementation strategies for improving project performance
          while  concurrently  streamlining the RI/FS  schedule.  These
          initiatives  attempt to  provide  a  realistic  strategy for
          implementing a phased RI/FS  schedule that would meet CERCLA
          objectives without  requiring major changes to the remedial.
          program.

     Reorganization  and reallocation  of  program responsibilities  was another
significant initiative during  the  year.  Early in the year, in anticipation of
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                 Progress Toward Implementing Superfund: Fiscal Year 1987


the CERCLA amendments, EPA  decided to restructure the Office of Emergency and
Remedial Response  (OERR)  to improve management's ability  to  implement the new
law, to focus  efforts on meeting statutory goals and schedules,  and to facilitate
the drafting  of  major  rules,  such as the NCP and HRS  revisions.   EPA Regional
offices have assumed an increasingly important role in the Superfund program as
a result of increasing internal delegation of program responsibilities  to the
Regional level and expansion of  computer capabilities for planning workloads and
tracking program progress.

     The removal  program,  supported by  four  zone ERGS  contractors,  developed
several contracts  initiatives that will  be implemented over  the next  2  years.
EPA implemented a strategy for awarding smaller removal contracts,  "mini-ERCS,"
on a Regional  basis.   EPA also plans  to provide additional coverage by splitting
one of the  ERGS zones into two smaller zones and awarding  a new contract for each
of them.

     Additionally, EPA is developing a new contracting approach (projected for
FY89) that  involves  prequalifying contractors within  each Region  (or an even
smaller geographical area) so that when a specific removal is required within a
certain  area, a  contractor  can be  chosen  from  among  the  select  group  of
prequalified firms in that area.

     As noted earlier,  EPA created a second generation CERCLIS by incorporating
into  CERCLIS  part  of  the  information and data contained  in  five  different
systems: CERCLIS  (first generation); the Superfund Comprehensive Accomplishments
Plan  (SCAP);  the  Removal  Tracking System;  the Case Management System;  and the
Remedial/Removal  Financial  System  Site  File.   The  expanded  CERCLIS  is  the
national Superfund management, tracking, and reporting tool.  Site-specific data
files became  fully operational  on November 1,  1987,  and,  by  January  1, 1988,
CERCLIS was being used to track the SCAP and Agency-wide progress measures.

     The SCAP is the planning mechanism that drives the allocation of resources
for remedial  activities.  With  the incorporation of the SCAP into  the CERCLIS
management system, the  Regions became responsible for the planning and reporting
that  determine   the   adequacy   of  budgetary  allotments  and how   Regional
accomplishments  are  reported.    To make the  SCAP a  better  planning  and site
management  tool,   EPA  used  an   integrated approach  to  SCAP  development  and
maintenance,  which was implemented in several  ways:

     •    Target  setting  and reporting for Fund-financed  activities
          and enforcement/PRP activities were  combined;

     •    Uniform reporting formats  combining  removal, remedial,  and
          enforcement information were developed;

     •    The  enforcement case  budget  was  integrated with the SCAP;
          and

     •    Regions  began  planning  the  use  of Technical  Enforcement
          Support contract  and  interagency agreement resources  on  a
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                 Progress Toward Implementing Superfund: Fiscal Year 1987


          site-specific basis, the basis on which remedial activities
          are planned.

     Finally, senior OSWER management and staff have spent a significant amount
of time identifying and resolving  the  complex  issues raised by integrating the
Resource Conservation and Recovery Act  (RCRA) and CERCLA programs in response to
the requirements of CERCLA section 121, which recognizes the significant impact
the regulations and policies established for one program can have on the other.
Their efforts will be reflected in both the NCP proposal and forthcoming manual
on Superfund compliance with  other  laws.   The  current focus of the RCRA/CERCLA
Task Force is the proposed RCRA section 3004 corrective action rule.

Other Implementation Activities

     EPA took a number of actions with regard to Federal facilities.  EPA added
32 Federal facilities to  the  NPL,  the  first Federal facilities to be included,
and another 16 were proposed for  listing.   In addition, EPA, the U.S. Department
of the Army,  and the State of Minnesota signed the first Interagency Agreement.
EPA also established the Federal Facilities Task Force, which works with States
and EPA Regional  offices  to ensure  that  Federal  facilities comply  with the
section 120 provision that Federal  facilities satisfy applicable CERCLA and RCRA
requirements.  EPA has 16  facilities subject to  this  provision and began in FY87
to prepare its Report to Congress on progress made to bring the facilities into
compliance with the provisions of section 120.

     EPA established  the  Federal Agency  Hazardous  Waste  Compliance  Docket to
make information  available  to the public about Federal facilities  and to give
notice  of  CERCLA  actions  concerning Federal  facilities.   The  initial  docket
listed  1,094  facilities.   In accordance  with  the 1987 Executive  Order 12580,
Federal departments and agencies are responsible for  conducting  PA/SIs  of the
Federal facilities they own or operate.   EPA established a  deadline of April 17,
1988,  for submission of Federal  facility pre-remedial activity reports.   Also,
EPA proposed regulations  implementing  section  120  restrictions on the transfer
of U.S.  government property on which a hazardous substance was  released, disposed
of, or stored for a year or more.

     Much of the Superfund program is implemented through contract services, and
EPA is continuing efforts to increase the proportion of contract dollars that is
awarded to minority firm contractors.  This year the value of the minority firm
share of Superfund contract  dollars  was  $38,000,000, which is 6 percent of the
$603,900,000 total obligated during the year.  Of the total,  direct: procurement
contracts represented $31,300,000 (9 percent of the  total  dollars awarded); the
share of cooperative agreement dollars awarded was $2,100,000 (22 percent); and
the share of interagency agreement dollars was $4,600,000  (2  percent).

     During  the  fiscal year, EPA  conducted several activities  to  promote the
participation of minority firms.   The Office of  Small and Disadvantaged Business
Utilization  (OSDBU) sought  the assistance of the  Minority Business Development
Agency  (MBDA)  of  the  Department  of Commerce.    EPA  issued  information  on
contracting processes and held conferences, seminars, and  training workshops to
inform  minority  firms  about Superfund contracting  opportunities.   Also,  other
                                       12

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


Federal  departments  and  agencies  involved  in  the  Superfund program  were
encouraged to increase awards to minority firms.   EPA requires  these departments
and agencies to submit reports on contracts  that  have been  awarded.

     EPA  Superfund  implementation  activities  are  funded  from  the  Hazardous
Substance Trust Fund.  Executive branch departments  and agencies other than EPA
use two sources of funding to  implement Superfund  activities:  the Trust Fund and
monies budgeted independently of Superfund  as part  of  the President's annual
budget  submission.     During  the   fiscal  year,  EPA  expended  a  total  of
$1,050,748,900  in Trust Fund monies  for  CERCLA implementation, including SARA
Title III activities.  Other Federal departments and agencies spent $478,193,900
to fund the implementation of their Superfund activities, including $66,148,000
in Trust  Fund  monies transferred via the  EPA  Superfund Interagency Budget and
site-specific interagency agreements.

     Congress  provided EPA  with $3,964,000,000  in  budget authority  for the
implementation  of CERCLA, as  amended, for  the 3-year  fiscal period 1987 through
1989.  The actual level of funds obligated  annually may be slightly less than the
level of budget authority provided.  EPA is working to collect  the data necessary
to include estimates for completion of CERCLA requirements in  the FY88 Report to
Congress.  EPA  is also developing an estimate of  unfunded liability beyond 1991
for projects currently in the remedial pipeline.  In  FY88,  the  Agency's ability
to forecast costs should be improved by promulgation  of the proposed NCP and by
gaining another year's experience in implementing the provisions that SARA added
to CERCLA.  Better coordination with other agencies  and departments also should
help refine projections.

     Finally, EPA participated in four Congressional  hearings before the Senate
Environment  and  Public  Works  Committee  on  Superfund  implementation.    No
implementation  hearings were  held by House committees.

Statutory Deadlines and Report Requirements

     Congress  imposed  seven deadlines on  EPA  in  FY87 through  provisions added
to CERCLA by SARA.   EPA met two of these deadlines:  promulgating revisions to
RQ regulations  under section  102(a), and soliciting  innovative  technologies for
research and development as required by section 311(b)(5)(B).  The following were
not submitted to Congress by  their  respective deadlines:  this  Report on CERCLA
implementation  progress,  required by  section 301(h)(l);  the report on progress
in the  research,  development, and  demonstration  programs,  required by section
311(e);  and  the study  on hazardous waste sites  on  Indian lands,  required by
section 126(c).  All of these reports have now been  submitted.

     Also, statutory deadlines established for promulgating procedures to notify
local  and State officials and  other  interested  persons  of limitations  on the
payment of claims under  section  lll(o)  and for submitting a report to Congress
under section 120(e)(5) on implementing CERCLA at EPA facilities were not met.
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                Progress Toward Implementing Superfund: Fiscal Year 1987


     In addition to providing an overview  of  EPA FY87 progress in implementing
CERCLA, this Report includes the following information specifically required by
CERCLA sections 301(h)(l)(A) through (G),  105(f), and 301(h)(2):

     •    In  response  to  the requirement  of section  301(h)(1)(A),
          Appendix  C  contains   a  detailed  description   of  each
          feasibility study completed during FY87.

     •    The  status  and  estimated  date  of  completion  of  each
          feasibility  study  and   remedial  and  enforcement  action,
          required by section 301(h)(l)(B)  and (F),  are summarized in
          section 2.4.   Detailed information  is  given in Appendix D,
          which also  contains  information on  feasibility  studies,
          remedial investigations  and,  as  required  by  301(h)(1)(C),
          remedial actions that will not meet previously established
          schedules.    It  also  includes  a  new  estimate  of  time  of
          completion.     The  status  of  enforcement  actions  and  a
          comparison of  FY87 remedial and enforcement  actions  with
          those undertaken in previous years, required by 301(h)(1)(F),
          is included in section 2.3.9.

     •    The evaluation of newly  developed technologies required by
          section 301(h)(l)(D) is described in Chapter 7.

     •    A discussion of the progress made in reducing the number of
          facilities subject to 5-year reviews under section 121(c),
          required by section 301(h)(1)(E),  is  included in section 2.5.
          Section  2.5  also contains  information that  satisfies  the
          requirements  of section  121(c) to report  to Congress:   (1)
          a list of facilities for which such a review is required; (2)
          the results of such reviews;  and (3) any actions taken as a
          result of such reviews.

     •    The   resource   estimates   for    completion   of   CERCLA
          implementation,  required  by  section  301(h)(1)(G),   are
          included in Chapter 13.

     •    Chapter 11  satisfies the  section 105(f) requirement that EPA
          describe the participation  of  minority firms  in contracts
          carried out under CERCLA.

     •    The  report  conducted under  section 301(h)(2)  by  the  EPA
          Inspector General on the  reasonableness and accuracy of this
          Report to Congress is found in Appendix F.
                                       14

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


2.0   RESPONDING TO RELEASES OF HAZARDOUS SUBSTANCES

     CERCLA  gives  the Federal government  authority to respond  to  uncontrolled
releases  of hazardous  substances  and to develop  long-term  solutions to  the
nation's gravest hazardous waste  problems.   CERCLA  provides  for  a broad program
of reporting, investigation, and  response  to releases  or  threats of releases of
any hazardous substance,  or of any  pollutant or  contaminant  that may present an
imminent and substantial  danger to  public  health, welfare,  or the environment.

     2.1  Notification and Reporting of Hazardous Substances

     2.1.1  Overview

     Sections  103(a) and  103(b)  of CERCLA  require that persons in  charge  of
vessels or facilities from which a hazardous  substance is  released in quantities
equal to or greater  than  its RQ immediately  notify  the  National  Response Center
(NRG).*

     Section 102(b)  of  CERCLA  establishes  one pound as the  standard RQ for  all
releases of  hazardous substances,  except  those  for which RQs were  established
pursuant to  section  311 of the  Clean Water Act.   Section 102(a)  authorizes  the
Administrator of EPA to adjust all  of  these  RQs  by  regulation, thereby allowing
the Federal  government  to focus  its resources on those releases that are most
likely  to  pose  potential  threats  to  public   health  and  welfare  and  the
environment.

     Under section 103(f)(2)  of CERCLA, the reporting  requirements  for certain
continuous releases  of hazardous  substances may be  less  stringent  than  those
otherwise specified  under sections  103(a)  and (b).   Section  103  of  CERCLA also
provides  a reporting  exemption  for  federally  permitted releases,  which  are
defined as releases  permitted under certain  other State or  Federal  programs.

     2.12  Past and Ongoing Activities

     On May  25,  1983,  EPA proposed a  rule to clarify procedures for reporting
releases  of CERCLA  hazardous  substances and   to  adjust  RQs   for  387  CERCLA
hazardous  substances (48  FR 23552).    The  May  25,  1983,   Notice  of  Proposed
Rulemaking  (NPRM)  also compiled for  the  first  time the   list  of  hazardous
substances  defined under  section  101(14) of CERCLA.   On  April  4,  1985,  EPA
promulgated a  final  rule that clarified reporting  procedures and finalized  RQ
adjustments for 340 hazardous substances (50 FR  13514).  On  September 29,  1986,
EPA promulgated RQ adjustments for an additional  102 hazardous substances (50  FR
34534) .
       The NRG has the capability to accept release notifications on  a  24-hour
basis.  Its national toll-free number  is  (800)  424-8802;  in the  Washington,
B.C. metropolitan area, the number  is  (202) 267-2675.
                                      15

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


     2.13  Progress in Fiscal Year 1987

     On March 16, 1987,  EPA published two  proposed rules to  adjust  the  statutory
RQs for CERCLA  potential carcinogens and radionuclides (52 FR  8140  and 52 FR
8172).     Substantial effort   during  the  fiscal  year  culminated  in  several
rulemakings after the close of FY87.   On March 2,  1988,  EPA  published a proposed
rule to  adjust  the  RQs  for  lead and  lead  compounds  and  to  delist ammonium
thiosulfate as  a CERCLA hazardous substance  (53 FR  6762).  A proposed  rule
explaining the scope  of  the reduced reporting requirement for continuous releases
was issued on April  19,  1988  (53  FR  12868).   Also, the Agency published a  rule
on the reporting exemption  for federally  permitted releases (53 FR 27268,  July
19, 1988).

     On October 1,  1987,  the Emergency Response Notification System (ERNS) became
operational.  Notifications of releases reported directly to EPA Regional  offices
and to the U.S.  Coast Guard district  offices  are now entered electronically  into
a  central  data  base, along with  NRC reports.   ERNS  provides EPA with a  more
comprehensive perspective on  release notifications  nationwide.

     22 The Removal Program

     2.2.1  Overview

     Removal  actions,  authorized  under  CERCLA  section 104(a),  are  generally
short-term actions intended to respond to near-term threats  to human health and
the environment.   In some cases where  additional response  action is  otherwise
appropriate,  removal actions  serve to  protect the public  and the environment
until  a  long-term solution can be instituted;  in others,  the  removal action
suffices as the solution  to the problem.

     Removal  actions   may  include   the   following  activities:    treatment,
excavation,  pumping,   incineration,  barrier  installation,  provision  of an
alternate water supply,  or temporary relocation of residents. Superfund-financed
removals can  be conducted at both National Priorities  List (NPL) and  non-NPL
sites.    Removal  actions also  may be  conducted  and  financed  by potentially
responsible parties  (PRPs).

     SARA mandated two  significant changes in  the  removal program.  First,  SARA
amended CERCLA  section  104(c),  increasing the limits  on removal actions from  6
months and $1,000,000 to 1 year and $2,000,000. A new exemption  to these limits
can apply when "continued response  action is otherwise  appropriate and consistent
with the  remedial  action to  be   taken."    Second, CERCLA  section  104(a), as
amended, requires that  a removal  action contribute, to the  extent practicable,
to the efficient performance of a long-term remedial action.   EPA  issued guidance
in April 1987 to  implement  the section 104(a) provision and the section 104(c)
statutory  exemptions.    During  FY 1987,  EPA  approved 23 exemptions  to   the
statutory time  limit and  11 exemptions  to the  $2,000,000 ceiling.
                                       16

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


     222  Progress in Fiscal Year 1987

     The Agency initiated a total of 254 Fund-financed removal action starts and
restarts  and 195 removal  actions  were completed  using Superfund  resources  in
FY87.  This  is the second  largest number of completions since the program began
in December  1980.  The  enforcement program issued 67 administrative  orders for
removals, and PRPs started an additional 50 removals  and completed 31.   Removal
action  settlements  climbed  to  57,  totaling  more  than  $27,000,000.    At  10
facilities,  PRPs undertook independent  response actions.  A total of 85 removal
sites were  cleaned  up  during the  year; 83 were  Fund-financed,  and  two  were
financed by  PRPs.  A site  is determined to be cleaned up when no  further action
is anticipated.  Exhibit 2.2-1 lists, by State, the number  of removals  financed
by Superfund.

     222.1 Polychlorinated Biphenyl (PCB) Removals

     Removals conducted in response to  PCB  and/or dioxin  contamination during
FY87 comprised 20  percent  of total removals.  PCBs were found in  soil or oil;
dioxin contamination was usually found  only  in soil.

     In  early  1987,  PCB compounds were discovered  in  68  disposal  pits  along
natural gas pipelines owned by a private company.  In response, EPA appointed a
national  task  force to investigate the disposal  practices  of  the  interstate
natural gas  pipeline industry.  The task force initiated several  actions:

     •    A  nationally  coordinated effort  to identify  other  pipeline
          companies using  earthen disposal pits;

     •    Preliminary site assessments  to determine whether there was
          any immediate need for removal actions;  and

     •    Enforcement negotiations  with PRPs to  compel  them  to clean
          up any contamination.

     The  task  force ultimately   identified a  total  of  78  sites requiring
preliminary  site  assessments.    In all  cases,  the PRPs  undertook the  removal
actions.

     2222 The 1000th Removal  - Moreland Site

     EPA  initiated the  1000th Superfund emergency  removal action  in August 1987
at the Moreland  site in Commack,  New York.   The  Moreland site  typifies  EPA's
emergency removal actions.

     On  July  24,  1987,  the  New  York  State   Department   of   Environmental
Conservation (NYSDEC) alerted  EPA to two leaking  cylinders in a  field outside
of Commack,  New  York.   After  consulting a  cylinder  specialist  and  conferring
with  the  manufacturer,  EPA  determined  that  the  cylinders contained  hydrogen
fluoride, a highly corrosive substance  often fatal to humans  when inhaled.   One
of the  cylinders was  leaking through  the  valve  assembly,  and  the other  was
leaking through pinholes in its base.   The release of the cylinders'  contents
                                       17

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Progress Toward Implementing Superfund:  Fiscal Year 1987
                  Exhibit 2.2-1
       Fiscal 1987  Removals By State
                                 Fund-Financed
Region
Region 1






Region 2




Region 3





Region 4








Region 5






State
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Total
New Jersey
New York
Puerto Rico
Virgin Islands
Total
Delaware
Maryland
Pennsylvania
Virginia
West Virginia
Total
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Total
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Total
Starts
3
3
9
6
1
1
23(5)
9
25
1
1
36(8)
5
4
21
3
13
46(5)
3
5
12
6
3
16
3
2
50 (8)
2
7
10
1
8
7
35 (8)
Completions
3
2
7
3
0
1
16(3)
8
19
1
1
29(5)
3
1
17
6
_6
33(4)
3
4
11
4
1
13
4
1
41 (4)
3
12
5
0
5
5
30 (9)
                       18

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       Progress Toward Implementing Superfund: Fiscal Year 1987
                           Exhibit 2.2-1
                            (continued)
              Fiscal 1987 Removals By State
                                           Fund-Financed
Region
Region 6




Region 7




Region 8




Region 9





Region 10



State
Arkansas
New Mexico
Oklahoma
Texas
Total
Iowa
Kansas
Missouri
Nebraska
Total
Colorado
North Dakota
South Dakota
Wyoming
Total
Arizona
California
Guam
Hawaii
Nevada
Total
Idaho
Oregon
Washington
Total
Starts
4
1
0
13
18(4)
2
1
9
0
12(-)
9
0
1
1
11 (2)
3
10
0
1
1
15(4)
2
1
5
8(1)
Completions
3
1
1
12
17(3)
1
2
6
1
10(1)
3
1
0
0
4(2)
1
10
0
1
_o
12(3)
0
1
2
3(-)
Program Total
254 (45)
195 (34)
( ) = NPL sites.

Source: Removal Tracking System (RTS) Report of November 9, 1987.
                                19

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


presented  an  imminent  and  substantial  danger  to  public  health   and  the
environment.

     EPA began the  removal  action on July 24,  1987 by mobilizing  the  Emergency
Removal  Cleanup  Services personnel  and stabilizing  the two  cylinders in  two
overpack drums filled  with  lime.   On July 30 and  31  and August 1 and  2,  1987,
EPA emptied  the  two cylinders by allowing their  contents to gravity  feed into
an in-ground reactor vessel on site.  On August  11,  1987,  the empty  cylinders
were shipped back to  their manufacturer  in Cleveland,  Ohio,  for dismantling.
The removal  action was  officially  completed  on  September  3, 1987,  when  the
reactor vessel was removed.

     2223  The Environmental Response Team

     The Environmental Response  Team (ERT)  provides  training to Regions  and
States,  as  well  as technical  support for  difficult  or unusual  removal  and
remedial actions.   Regional  offices may request  the ERT's assistance if  the
Region determines that additional  technical  expertise is required to  remove  or
remediate a spill or other site contamination.   The ERT assisted all  10 Regional
CERCLA and RCRA offices with 195 instances of spills or  site contamination.   In
particular, the ERT  provided support  for the air monitoring conducted in the Love
Canal Habitability Study; the site-safety plan negotiations at the Bloomington,
Indiana, PCB site; the innovative technology demonstration at the  Peak Oil Site
in Tampa, Florida; and  the remedial activities for  ground-water contamination at
the North Road site in Reeders, Pennsylvania.

     During FY87, the  ERT presented  approximately 100 training courses to over
3,500 EPA, State, and  local employees.  Topics discussed include site safety;
sampling methods (air and other media);  first response;  incident mitigation;  and
ground-water treatment methods.

     222A  Monitoring of Removal Activities

     When CERCLA funds  are not used, EPA oversees the  cleanup  activities of  PRPs,
States, localities,  or  other parties to ensure that adequate cleanup takes place.
By the end of FY87,  EPA had conducted on-site monitoring for 422 cleanup actions
involving hazardous substances.

     222.5  Policy and Guidance

     During FY87, EPA issued seven policy and guidance documents to guide removal
program actions:

     •    Interim   final  guidance   on  State-lead  removal  actions
          (Guidance for  State-Lead Removal Actions,  OSWER Directive
          #9375.1-4-W,  July 10, 1987).  This  guidance sets forth  the
          policy and procedures for  awarding  to States the authority
          and funds necessary to lead a CERCLA-funded  removal action.
          The guidance  is  intended to provide  EPA Regions with a  new
          management tool for  handling their workload and will serve
          as  a   mechanism  for  the   further  sharing  of  program
          responsibilities  via cooperative  agreements  with States.
                                      20

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


          Under  this  program,  States  may  lead all,  or  part  of,
          non-time-critical  removal  actions at NPL and non-NPL sites.

     •    Interim guidance specifying  criteria and procedures for use
          of  the consistency  exemption  provided  in CERCLA  section
          104(c), which allows a removal action to continue beyond the
          $2,000,000,  12-month statutory limits if continued response
          action  is "otherwise  appropriate  and  consistent with  the
          remedial  action to be  taken"  (April 1987).

     •    Interim guidance on meeting the requirement of CERCLA section
          104  that  removals contribute to  efficient performance  of
          long-term remedial action  (April  1987).

     •    Interim final  guidance regarding new drinking water  action
          levels. including  a  new  decision  model  to  determine whether
          conditions at a site warrant  removal action (October 1987).

     •    Guidance  summarizing the  land disposal restrictions  under
          Resource  Conservation  and Recovery Act  (RCRA) section 3004
          for the remedial  program, and addressing the treatment  of
          Superfund removal wastes  prior  to  land  disposal  (August
          1987).

     •    Draft  guidance on the use of  alternative technologies  in
          remedial  response  --to  encourage and facilitate  the  use  of
          alternatives  to land  disposal in the  conduct  of  removal
          actions (May 1987).

     •    Draft guidance on engineering evaluation/cost analyses. which
          are performed to assess alternative removal actions in terms
          of their appropriateness, feasibility, and cost effectiveness
          (June 1987).

     223  Status of Removal Activities in Fiscal Year 1987 Compared with 1981-86

     Since  the  beginning of  the  Superfund  program,  the  number  of  completed
removals has  jumped from 18 in  FY81 to a  high of 201 in  FY84.   In  FY87,  EPA
completed 195  removal actions.   A  several-month delay in receiving  the  1987
appropriation caused  a  reduction  of  the  number  of new  starts and  completed
removals (see Exhibit 2.2-2).

     The type of  completed  removals has varied over time  (see  Exhibit  2.2-3).
In FY84,  63  (31 percent) of all Fund-financed removals occurred at inactive waste
management facilities.   During FY87,  37 (19  percent) of all removals occurred at
inactive  waste  management  facilities.   Transportation-related removals  have
dropped from 7  (3.5 percent) of all removals  in  FY84 to  zero in FY87.  Forty-
eight of  the FY84  and 53 of  the  FY87  removals  were  in  response to midnight
dumping.
                                       21

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               Progress Toward Implementing Superfund: Fiscal Year 1987
                             Exhibit 2.2-2
                 Removal Actions by Fiscal Year
              1980   1981  1982  1983   1984  1985  1986   1987   Total
  PRP*
  Financed

  Fund
  Financed
  Total
0
7
7
0
28
28
1
60
61
10
129
139
62
208
270
86
196
282
58
175
233
50
254
304
267
1,057
1,324
Completions
              1980  1981  1982   1983   1984  1985   1986   1987  Total
  PRP*
  Financed

  Fund
  Financed
  Total
0

0

0
 0

18

18
 1      0    28    55     24    31    139


66    108   201   153    152   195    893


67    108   229   208    176   226   1,032
 PRP = potentially responsible party.
                                 22

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                 Progress Toward Implementing Superfund: Fiscal Year 1987
                                  Exhibit 2.2-3
             Completed  Removals By Incident Category
                       1981   1982   1983    1984    1985    1986   1987
   Active Production
   Facility

   Inactive Production
   Facility

   Inactive Waste
   Management Facility

   Other

   Midnight Dump
0
3
12
y
1
2
5
13
29
5
14
8
23
46
7
24
12
34
63
44
48
13
32
47
21
40
10
40
25
43
34
12
32
37
61
53
Note:  The "Other" category Includes transportation-related Incidents,
active waste management facilities, and miscellaneous Incidents.
                                      23

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     23  The Remedial Program

     23.1  Overview

     A  "remedial  action" is a  longer-term cleanup  action intended  to  address
non-emergency  situations and  problems  more  complex than  those  that  can  be
addressed by removal actions.  The Remedial  Program  consists  of activities that
fall into three categories or phases:   (1) the pre-remedial phase,  In which the
extent of contamination at a site is assessed and those sites  that represent the
highest priority  for cleanup are identified;  (2) the remedial  action phase,  in
which  the  remedy is  designed  and  implemented; and  (3)  the  operation  and
maintenance phase, in which site upkeep and monitoring activities occur with the
remedy in place.  The steps  in the three phases of the program are  described in
more detail below.

     EPA's enforcement  program  plays an important role  in maximizing Superfund
site cleanups,  particularly  in the  remedial  program context.   The enforcement
program  has two  major  components:   negotiating  voluntary  settlements  with
potentially responsible  parties (PRPs)  and  taking  enforcement  actions  against
PRPs.   A fundamental goal of the enforcement  program is  to facilitate voluntary
settlements with PRPs.   When settlement negotiations do not result in agreement,
EPA has  two alternative  courses  of action.   The Agency  may take an enforcement
action to compel private party cleanup, or it may use Superfund money to finance
a government action and seek  recovery of  such  costs from PRPs throug^h the courts.

     SARA strengthened the enforcement program by codifying the existing CERCLA
settlement policy, establishing new authorities and  procedures  that, facilitate
private-party and  Fund  cleanups,  and adding new authorities  for imposing civil
and criminal penalties  for  failure  to comply with  the  statutory provisions  of
CERCLA that pertain to notification  and  reporting.

     232  Inventory of Hazardous Substance Releases

     EPA's CERCLA  Information System (CERCLIS) includes  a national  inventory of
all hazardous waste sites potentially appropriate for listing on the NPL.  Sites
are proposed for inclusion on  the  NPL as a  result  of citizen's petitions,  an
incident at the site, or  observation by  Federal,  State,  or  local officials.

     Progress in Fiscal Year 1987

     From FY80  through  FY86, the number of sites included in  CERCLIS grew from
8,000 to 25,194.  At the end of FY87, 27,571  sites were inventoried, an increase
of 2,377  sites  from October  1986.   The annual  number of sites  in the inventory
from FY80 through  FY87  is shown  in  Exhibit 2.3-1.

     233  Preliminary Assessments

     For  each site in  the inventory, EPA uses  existing  information to evaluate
the magnitude  of the potential  hazard at a  site,  identify  the source  and the
nature of the release, and identify  any  potentially  responsible parties.  Based
on the  results  of this  preliminary assessment  (PA),   EPA determines if the site
merits further  investigation.  The  PA does not normally  include a site visit or
                                       24

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                Progress Toward Implementing Superfund:  Fiscal Year 1987
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                                          25

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                 Progress Toward Implementing Super-fund:  Fiscal Year 1987


sampling.  CERCLA section 105(d) specifies that any  individual may petition EPA
to perform a PA and that EPA has up to  one year to respond  to  the  petition.

     Progress in Fiscal Year 1987

     Between FY80 and the end of FY87,  24,185 PAs  were conducted; 4,001 PAs  were
completed in FY87.  The  annual number of PAs conducted from FY80 through FY87 are
shown in Exhibit 2.3-1.

     EPA met the CERCLA section 116 goal for  completing PAs by January 1, 1988,
at those sites in CERCLIS as  of October 17,  1986.  The Agency also developed  a
strategy in FY87 to modify the PA to identify more effectively those  sites  that
require site inspections (Sis).   This strategy includes increasing the level of
effort for  an average  PA  from  50 hours  to  approximately  75  hours to  include
activities  such  as  off-site  reconnaissance,  and the  application  of  technical
evaluation  criteria,  professional  judgment,  and other  technical factors  for
assigning priority to sites needing Sis.  Revisions to the  guidance  on  conducting
PAs were made in FY87 to incorporate this strategy.   The new PA guidance will be
released to Regions in  the second quarter of  FY88.

     EPA expects that it can meet the requirements of CERCLA section  105(d) for
completing  PA  petitions within  12  months of their receipt and has  developed
guidance on  this requirement.   EPA Regional  offices report  fewer  than 20 PA
petitions were received during FY87.

     23.4  Site Inspections

     Site  Inspections   (Sis)  are performed  at sites  where PAs  indicate  that
additional studies are warranted to evaluate  potential hazards.  On average, in
a given year, approximately 80 percent of PAs have indicated the  need  for an SI.
The  SI   consists  of  a visual  L 'spection  of  the   site  and  usually  includes
collection and chemical analysis of a limited number  of samples of  environmental
media, e.g.,  soil,  surface  water,  or  ground water.  There are  several major
purposes for a SI:   (1)  to  determine  which  releases pose no  current or potential
threat to public health and the environment;  (2)  to determine if there  is any
immediate  threat to  persons living  or working  near  the  release  that might
necessitate  an  immediate   removal  action;   and  (3)  to   collect   data, where
appropriate, to determine whether the site should be included  on the  NPL.

     Progress in Fiscal Year 1987

     Between  FY80  and  the  end  of FY87,  7,785  Sis  were  completed,  with 1,343
completed in FY87 alone.   The annual number of Sis conducted from FY80 through
FY87 is shown in Exhibit 2.3-1.

     Under  section  116, Sis  (where  warranted)  are  to be conducted by January
1989 for all sites in CERCLIS as of October 17, 1986.  Although  the Agency  does
not believe it will be able to achieve this goal,  guidance was  developed in  FY87
to enable the Agency  to devote  more  resources to those sites most likely to be
proposed for the NPL.   The guidance also includes details on new aspects of the
                                      26

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


SI necessary  to support  the revised HRS  that the  Agency is  proposing.   The
revised guidance will be sent to the Regions in FY88.

     23.5  Hazard Ranking System

     The Hazard  Ranking System  (HRS)  was designed  to  be a screening tool that
would allow EPA  to  rank sites quickly  using data and information from the SI.
The current HRS  score is a  reflection  of  a site's potential  to cause harm to
human health  or the  environment,  as a result of  the  migration  of hazardous
substances through ground water, surface water, or  air.   The overall HRS score
is a composite of separate scores for each of these contaminant migration routes.
The score for each route is  obtained by  assigning  numerical values  (according to
prescribed guidelines) to a  set of factors that characterize the potential of the
release to cause harm.   Sites with HRS  scores  of  28.50 or greater are eligible
for inclusion  on the NPL.   The  28.50  threshold value was initially chosen to
yield an NPL of at least 400  sites,  as originally required by  CERCLA,  not because
it represents any threshold in the  significance of the  risks presented by sites.
EPA is reviewing the effect  of this threshold,  and may change it as  a result of
the revisions that are now being made to the HRS methodology.

     CERCLA, as amended by SARA,  mandates that EPA1s revision of the HRS should
be guided by certain  specific criteria.   Section  105 requires EPA to amend the
HRS to ensure "to the maximum extent feasible,  that the HRS accurately assesses
the relative degree of  risk  to human health and the environment posed by sites
and facilities subject to review."   Section 105 also directed EPA to consider a
number  of  specific   factors in  its  review  of  the  HRS:    the  effect  that
contamination of  surface  water  has on  the  use of that  water  for  drinking and
recreational purposes and the threat that contamination poses to the human food
chain and to ambient air.  Section 118 directs EPA to assign a high  priority to
facilities whose releases have led to the closing of drinking water wells or to
contamination of a principal drinking water  supply.   Section  125  requires EPA to
assess a number of factors in relation to the scoring of sites containing fly ash
wastes.

     Progress in Fiscal Year 1987

     In  FY87,  the  Agency  began  revising the  HRS  to comply  with  CERCLA
requirements.   The revised  HRS will  be proposed  in  early FY89.   To facilitate
the revision process,  an HRS revisions workgroup was  established and  met monthly
during most of the fiscal year.  A testing  program was implemented to evaluate
sites according to the revised HRS and three other site evaluation systems.  EPA
also convened a  site-ranking panel  to  evaluate and  rank 20  sites  according to
their perceived  risk levels.   This  exercise  was  conducted to obtain expert
judgments to serve as the baseline  with which to compare  site evaluation models
and  to  gain  a  better  understanding  of  the  relative weights  that  should be
assigned to certain  factors.  The workgroup  also prepared  an economic impact
analysis of the  proposed  revisions  to  the HRS, and  planned  procedures for the
field testing of the revised HRS  that EPA will conduct in FY88.
                                       27

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     23.6  Listing on the National Priorities List

     The main purpose of the National Priorities List (NPL) is to identify sites
that appear  to  present  a significant risk to public health  or  the environment.
The National Contingency Plan (NCP) establishes that a site must be placed on the
NPL before it  can  undergo Fund-financed  remedial  action.   The NPL  does  not,
however, determine  priorities  for  removal  actions;  EPA  may take removal actions
at any  site,  whether listed or not,  if the  site meets the  criteria  in section
300.65(b)  of the 1985 NCP.   Likewise, EPA  may take enforcement  actions  under
CERCLA against  PRPs regardless of  whether  a  site is on  the NPL.   As a practical
matter, however, the focus of  EPA's  enforcement actions has been on NPL sites.

     EPA follows the Administrative  Procedure  Act  (APA) rulemaking  procedures
to add sites to  the NPL.  These procedures involve  proposing sites in the Federal
Register,  soliciting  comments  on the  proposals,  and publishing  a list  of  sites
ultimately chosen for inclusion on the NPL in the Federal Register.

     Progress in Fiscal Year 1987

     At the end  of  FY86, 703 sites were listed  on the NPL and an additional 184
sites had  been  proposed for  inclusion.  In January 1987, EPA proposed 64  sites
for inclusion on the NPL.  The proposed update included one Federal facility site
and sites  located  in  24 of  the  50  States, the  District  of  Columbia, and  6
territories.   In July  1987,  99 sites (including  32  Federal facilities)  were
added, bringing  the total number of  sites  on the NPL to 802,  with an additional
149 sites proposed  for  inclusion.

     Of the  States  and  Territories,  eight had no sites listed on the  NPL  as of
July 1987:   Alaska, American  Samoa, the  Commonwealth  of the Northern Mariana
Islands, the  District  of Columbia,  Hawaii,  Nevada, the Trust Territory of the
Pacific Islands, and the Virgin Islands.  New Jersey had  the largest number of
listed sites (96),  followed by New York (63), Pennsylvania  (61),  Michigan  (58),
and California  (48).   The map  in  Exhibit 2.3-2  shows  the location of all NPL
sites.   Exhibit 2.3-3 shows  the  number of  listed  Federal and non-Federal NPL
sites and  proposed  sites  in each  State, as  of  July 1987.  The number of  sites
that have  been added to the NPL  each year  from FY83  through FY87  is shown in
Exhibit 2.3-4.  During FY87,  the Agency also began work on Update 7 and, on June
24, 1988, proposed 229  new  sites, including 14 Federal sites,  for NPL listing (53
FR 23988).

     23.7  Remedial Investigation and Feasibility Study

     During  the  remedial investigation (RI), data  are  collected  on all aspects
of the site, including the geologic  and hydrologic  characteristics of the  site,
the nature of the on-site contaminants, and the characteristics  and proximity of
the population  near the site.  Numerous  samples of air, ground  water, surface
water, soil, and contaminants are analyzed.  A Superfund Public Health Assessment
based  on  these data  determines  the  risks  posed to human  health and  the
environment by  the  site contamination.
                                       28

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                      Progress Toward Implementing Superfund:  Fiscal Year 1987
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                                                29

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             Progress Toward Implementing Superfund:  Fiscal Year 1987
                                 Exhibit 2.3-3
                         National Priorities List
                        Sites Per State/Territory
                                 July 1987
Region
                                   Listed
                                       Proposed
State
Non-Federal  Federal  Non-Federal  Federal  Total
Region  1
Region  2
Region 3
Region 4
Region 5
            Connecticut            7      0
            Maine                 5      1
            Massachusetts         21      0
            New Hampshire        13      0
            Rhode Island           8      0
            Vermont               2      0
            New Jersey           94      2
            New York             62      1
            Puerto Rico            8      0
            Virgin Islands           0      0
            Delaware             12       0
            District of              00
             Columbia
            Maryland              7       0
            Pennsylvania          60       1
            Virginia               10       1
            West Virginia           5       0
            Alabama               8       1
            Florida                34       0
            Georgia                3       1
            Kentucky              10       0
            Mississippi             2       0
            North Carolina          9       0
            South Carolina         12       0
            Tennessee             8       1
            Illinois                15       2
            Indiana               24       0
            Michigan              58       0
            Minnesota            39       1
            Ohio                 28       0
            Wisconsin            32       0
                                         1
                                         1
                                         0
                                         0
                                         0
                                         0
                                         3
                                         4
                                         0
                                         0
                                         5
                                         0

                                         0
                                        17
                                         8
                                         1
                                         0
                                         5
                                         3
                                         0
                                         0
                                         2
                                         3
                                         1
                                         8
                                         5
                                        11
                                         0
                                         2
                                         1
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    1
                                    0
                                    0
                                    0
                                    1
                                    0

                                    2
                                    2
                                    0
                                    0
                                    1
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    2
                                    0
                                    0
                                    0
                                    0
                                    0
  8
  7
 21
 13
  8
  2
100
 67
  8
  0
 18
  0

  9
 80
 19
  6
 10
 39
  7
 10
  2
 11
 15
 10
 27
 29
 69
 40
 30
 33
                                     30

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             Progress Toward Implementing Superfund: Fiscal Year 1987
                               Exhibit 2.3-3
                                (continued)
                         National  Priorities List
                        Sites Per  State/Territory
                               July 1987
Region
                                  Listed
State
                                      Proposed
Non-Federal Federal  Non-Federal  Federal Total
Region 6
Region 7
Region 8
Region 9
Region 10
           Arkansas
           Louisiana
           New Mexico
           Oklahoma
           Texas
           Iowa
           Kansas
           Missouri
           Nebraska
           Colorado
           Montana
           North Dakota
           South Dakota
           Utah
           Wyoming
           American Samoa
           Arizona
           California
           Commonwealth
             of Marianas
           Guam
           Hawaii
           Nevada
           Trust Territories
           Alaska
           Idaho
           Oregon
           Washington
  Total
                   9
                   6
                   4
                   5
                  21
                   7
                   7
                  12
                   2
                  12
                   8
                   1
                   1
                   3
                   1
                   0
                   6
                  40
                   0

                   1
                   0
                   0
                   0
                   0
                   4
                   4
                  20

                 770
             0
             0
             0
             1
             1
             0
             0
             2
             1
             1
             0
             0
             0
             2
             0
             0
             0
             8
             0

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             0
             0
             0
             0
             0
             1
           _3

            32
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0
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0
0
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_3
133    16
                  10
                   8
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                  26
                  13
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                   9
                  63
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  6
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951
                                   31

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
                                   Exhibit 2.3-4
                    Historical  National  Priorities List Sites
Fiscal
Year
1987
1986
1985
1984
1983
•This total
Annual Number
of Sites
99
170
3
132
406
reflects all sites deleted from the NPL.
Cumulative
Total
802"
703
541
538
406

     The feasibility  study  (FS)  (often conducted  concurrently with the RI)  is
conducted to analyze alternative approaches that can be used to clean up a  site.
Treatment technologies and non-treatment technologies  that  meet overall cleanup
objectives  also are  identified.   The  alternatives  analyzed  in  the FS  are
developed by screening the  universe of potentially applicable  technologies and
process options. By using readily available information on contaminant types and
concentrations  and  site   conditions  from   the   RI  site   characterization,
technologies and process options that clearly are not appropriate  are  screened
out.

     Each alternative in the FS  is  evaluated with  respect to  the following nine
criteria.  These criteria fall into three  groups:   threshold criteria that  every
remedy  must meet  (1-2);  primary  balancing  criteria that  are  used   to  weigh
tradeoffs among remedies (3-7); and modifying criteria that  are considered  after
public comment has been formally received  (8-9).

     (1)  Overall protection of  human health  and the  environment;
                                       32

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     (2)  Compliance  with  applicable  or  relevant  and appropriate
          requirements;

     (3)  Long-term effectiveness  and permanence;

     (4)  Reduction of  toxicity, mobility,  or  volume;

     (5)  Short-term effectiveness;

     (6)  Feasibility;

     (7)  Cost;

     (8)  State acceptance;  and

     (9)  Community acceptance.

The results of this analysis provide  the  rationale  for  selecting  a  final  remedy
that provides the  best balance among the inevitable evaluation criteria  trade-
offs.

     Treatability  studies  determine  the  relative  effectiveness  of  treatment
technologies that  are  identified as possibilities for the site.   The results  of
treatability studies also are  used as bases  for  developing new technologies and
helping EPA meet  the  new statutory preference in CERCLA for remedies that use
treatment to reduce the volume, toxicity, or mobility of hazardous substances  at
a site or operable unit within a site.

     CERCLA section  104(a)(l)  allows PRPs  to conduct  an  RI/FSs, provided the
RI/FSs meet  EPA's standards.  The lead agency  oversees  the process  to  ensure
that the  RI/FS  is adequate  for  identifying an  appropriate  remedy  and that  it
will meet all relevant requirements.   In the event of a  PRP-conducted RI/FS, the
Agency  develops  an  oversight plan  that  includes a  schedule  for  oversight
activities.   Generally,  activities  include  reviewing  project plans  and work
products, overseeing the conduct of field activities, and meeting with PRPs.

     Progress in Fiscal Year 1987

     The SARA amendments to  CERCLA include a number of  provisions affecting the
selection  of  remedies  at  Superfund  sites.    EPA sent  to the Regions late  in
December  1986  and in  July  1987 interim guidance   on developing  and  selecting
remedies that comply with CERCLA provisions.  EPA also sent to Regional  personnel
in July  1987  interim  guidance on compliance  with  applicable or relevant and
appropriate requirements.   These  interim guidance  documents will be superseded
by final guidance  documents  that  are  scheduled for  distribution to the Regions
in FY88.

     The Agency took  a number  of  actions in FY87 to improve the efficiency  of
the RI/FS process  and to incorporate changes to  the RI/FS process in compliance
                                       33

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


with CERCLA requirements.   The following two major  project management support
activities were initiated in FY87:

     •    The Alternative Remedial Contracts Strategy (ARCS); and

     •    The RI/FS improvements initiative.

     Key components  of ARCS  include  promoting  continuity  of performance from
RI/FS  to construction management,  increasing  the  level  of  competition  for
contract awards,  developing  incentives to  promote  superior  performance,  and
facilitating the  delegation of contract management  to  the Regions.   The ARCS
concept was fully  developed and procurement actions were  initiated In two EPA
Regions.   More  details on the ARCS program are provided  in  Chapter  6 of this
Report.

     An RI/FS improvements strategy was forwarded to Regional personnel in July
1987.  The strategy includes several initiatives aimed at improving performance
on RI/FS projects  and  proposes  implementation strategies  for improving project
performance, while concurrently streamlining the  RI/FS  schedule.   The strategy
is  intended  to be integrated with concepts from the Data Quality Objectives
guidance, the Compendium of Field Standard Operation Procedures, and the guides
for remedial project managers (RPMs).

     The initiative attempts to provide a realistic strategy for implementing a
phased RI/FS that would facilitate compliance with statutory objectives without
requiring major changes to the remedial program.   This RI/FS improvements effort
has three main  objectives:   to limit project planning activities  to  a 3-month
period following project initiation,  with  the ultimate  goal  of  reducing the
overall RI/FS process  to  an  18-month  schedule;  to reduce  overall  costs;  and to
improve the technical quality of RI/FSs.

     Just after  the  close of FY87, EPA issued  interim guidance that  set forth
its policy and procedures for PRP participation  in RI/FS preparation.  EPA plans
to issue guidance  that will  identify  the procedures  to be followed by RPMs and
PRPs to properly initiate, control, and monitor PRP conducted RI/FSs.

     In FY87, the  Agency  achieved  its  targeted  goal  for  RI/FS starts.   A total
of 183 RI/FSs were  started:  127 Fund-financed RI/FSs  and 56  PRP-financed RI/FSs.
Exhibit 2.3-5 shows  that  76  of  the Fund-financed  RI/FSs  were first starts; the
remaining 51 were  subsequent starts.  Forty-seven of the PRP-financed RI/FSs in
FY87 were first starts and nine were subsequent  starts.  Exhibit 2.3-6  shows the
annual number of RI/FS starts from FY80 through FY87.  At the end of FY86, over
600 RI/FSs had been started.  Under CERCLA  section 116 goals, an additional 275
RI/FSs are to begin by October 1989.

     Section 301(h)(l)(A) requires that summaries of each FS conducted during a
fiscal year be  submitted  to  Congress  annually.   EPA  treats records of decision
(RODs) as  essentially equivalent  to  FS  summaries.   The  FS summaries  for this
Report, therefore, are based on RODs signed during FY87 and include information
on the major contaminants of concern at a site,  the remedial  alternatives
                                       34

-------
                    Progress Toward Implementing Superfund:  Fiscal Year 1987
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                Progress Toward Implementing Superfund: Fiscal Year 1987


                              Exhibit 2.3-6
 Historical Superfund Remedial Investigation/Feasibility Study
                  Starts and Records of Decision
RI/FS
Starts
   PRP*
   Financed

   Fund
   Financed

   Total
21
21
                       1982
              1983    1984   1985    1986    1987   Total
32


35
                11
112
                28     59      46      56    203
127     129
123     155
37     127    585
        188      83     183    788
RODS
Signed
   PRP*
   Financed

   Fund
   Financed

   Total
                       1982   1983    1984    1985   1986   1987   Total
                13
                13
                35
                38
                 3


                65


                68
                                       22
                62
                84
                                       31
                               59
        44    223
        75    282
•PRP = potentially responsible party.

Note: Only NPL-llsted, non-Federal sites are Included.
RI/FS starts Include both first and subsequent action starts.
                                    36

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


considered, and  the  selected  remedy.   Appendix C contains the  FS  summaries  for
FY87.

     23.8  Record of Decision/Selection of Remedy

     The decisionmaking process  that  culminates in the selection  of  the  remedy
for a  site  is a multi-step process.   The alternatives  analyzed in the  FS  are
developed by  screening  the  universe  of potentially applicable  technologies  and
process options.   By using readily available  information on contaminant  types
and  concentrations  and site  conditions  from the  RI  site characterization,
technologies  and process options  that clearly are not appropriate  are  screened
out.   Each remaining  alternative is  evaluated with respect  to nine  criteria
developed  to  address  the   statutory  requirements  and goals.   Based  on this
evaluation,   the  Regional   Administrator  or  Assistant   Administrator,   in
consultation with relevant  State personnel, selects  the  remedy  for a  site.

     After  a  remedy is selected,  a  ROD  is  prepared.   The ROD is a  decision
document that identifies the  selected remedy  from a range of possible  remedies
identified in the FS.  The centerpiece of  the  administrative record,  the  ROD is
the document by which a court may judge the soundness of  the Agency's decisions
about appropriate remedial  action for  a site.

     Because  the ROD has an important  legal and technical role,  it must contain
an accurate and  complete summary  of  the site.   The ROD,  therefore, includes an
assessment of the threat posed by the  site, a  description of the remedy, a clear
justification  for the  remedy selected for  a site,  and a  description of  the
relative advantages  and disadvantages of each alternative considered.  The  ROD
also  contains a  brief  description of how the  selected remedy satisfies  the
statutory requirements of CERCLA section 121.  The selected  remedy must:

     •    Be protective of human health and the environment;

     •    Attain applicable or  relevant and appropriate  requirements
          (ARARs) (or provide grounds  for  invoking a waiver);

     •    Be  cost-effective;

     •    Use permanent solutions and  alternative  treatment technologies
          or  resource  recovery  technologies  to   the  maximum  extent
          practicable; and

     •    Address whether  the preference  for  treatment  that reduces
          toxicity,  mobility,  or volume   as  a principal element  is
          satisfied, or provide an explanation  as  to why  it is  not
          satisfied.

     Progress in  Fiscal Year 1987

     In June and July 1987,  EPA  sponsored  three ROD workshops around the country
to advise RPMs on how to prepare FY87 RODs to  ensure compliance with CERCLA.   The
interim guidance on remedy  selection  issued in July also  included information on
                                       37

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


new components of the ROD required by CERCLA.  This  interim guidance explains the
nine  key  criteria to  be  considered  in  evaluating  and comparing  remedial
alternatives and  the statutory  findings about the  selected remedy that must be
included in the RODs.

     The Agency  also  began to  revise  the  ROD guidance in FY87  to incorporate
provisions added  to  CERCLA by  SARA and six years  of program  experience.   The
draft guidance, now in progress, includes procedures  to  follow  in developing the
proposed plan,  a new document  for  promoting public  participation required by
CERCLA  section 117,  and  also  presents  new  procedural processes  designed to
increase State  involvement  in remedial decisionmaking.   Finally,  the guidance
discusses formats  for presenting information  in  the  ROD and procedures for the
ROD development process.

     Summary of Fiscal Year 1987 Selected Remedies

     The 75 RODs  signed in  FY87 represent  approximately 90 percent of the goal
for the fiscal year;  58 were for first-start actions and 17 were for subsequent
starts  (Exhibit 2.3-5).  Exhibit 2.3-6  shows  the annual number of RODs signed,
both for Fund-financed and potentially responsible-party-financed remedial action
through FY87.

     Remedies selected in RODs can be divided into three  categories:  (1) source-
control remedies that use treatment as a principal component (e.g., incineration,
stabilization,  solidification,   chemical   fixation,   and   biodegradation);  (2)
source-control remedies that use containment as a principal component (e.g., on-
site or off-site landfill  disposal and soil  capping);  and  (3) non-source control
remedies (including no-action remedies, or those that address only ground water
or provide alternative water supplies).

     To address  the various types  and sources of  contamination at a  site, the
ROD often  involves more than one remedial  component.   Treatment-based source-
control remedies  also  may  use containment technologies.   For  example,  the ash
from an  incinerator may be  disposed of in an off-site  landfill.   In addition,
remedies classified in the containment-based and treatment-based source-control
categories also may have ground-water components. For example,  a landfill remedy
may have a ground-water component for pumping and treating  an  aquifer.

     The 75 RODs signed in FY87 involve a total of 119 remedial components that
are summarized  in  Exhibit 2.3-7.  Thirty-two  of  these remedial components will
employ  at  least one  type  of treatment  that will permanently and significantly
reduce the volume,  toxicity, or mobility of the hazardous substances, pollutants,
and  contaminants  at   a   site:    13  will   employ  thermal  destruction;  7
solidification;  2  stabilization; 3  aeration;  2 soil washing and  flushing;  1
biodegradation; and 4 will employ other treatments.

     Thirty-five remedies  involve containment components to address non-residual
waste.  On-site containment is  involved in 24 remedies; off-site containment in
three; and temporary storage in eight.  Ground-water pump  and  treatment actions
are included in 32 of the  selected remedies.   Finally, thirteen remedies provide
for alternative water supplies, and seven recommend no  further action.
                                      38

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      Progress Toward Implementing Superfund:  Fiscal Year 1987
                        Exhibit 2.3-7
           Summary of Remedy Selection in
    Records of Decision Signed During Fiscal 1987
Remedy Fund-Lead
Source Control-
Treatment Techniques:
Incineration/Thermal
Destruction
Solidification
Stabilization/
Neutralization
Volatilization/Aeration
Soil Washing/Flushing
Biodegradation/Land
Application
Other
Total
Source Control-Containment:
On-site Containment
Temporary Storage
Off-site Disposal
Total
Non-Source-Control:
Ground-water Treatment
Alternative Water
Supply
No Further Action
Total

10
5
0
2
2
0
^
22

8
8
_1
17

18
9
4
3T
Enforcement

3
2
2
1
0
1
_1
10

16
0
_2
18

14
4
3
2T
Total

13
7
2
3
2
1
_4
32

24
8
_3
35

32
13
7
"52
Source: ROD Annual Summary.
                           39

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


     A completed RI/FS  sometimes results in a ROD recommendation that "no further
action" is required to protect human health and the environment for  one or more
operable units, even though the HRS  score  for  the  site  indicated a site response
was warranted.  There may be several possible reasons  for such an outcome.  The
HRS,  as  a general  screening  tool,  uses  a  limited data  set, while  an RI/FS
collects and generates  much more data to more completely characterize the threat.
Alternatively, a  previous  removal action at  the  site, or  the  completion of a
previous operable unit, may reduce the  threat  so that further  response action is
unwarranted.

     CERCLA  section 121   requires  that  permanent  solutions  and   alternative
treatment  technologies be used  at  Superfund  sites  to  the maximum  extent
practicable.    In  addition, SARA added  a statutory preference for remedies that
use treatment as a principal  element to reduce the toxicity, mobility, or volume
of contaminants.   The  use  of  treatment-based source  control  remedies has been
increasing steadily over the  history of the  Superfund program.   Exhibit 2.3-8
illustrates  historical data  on   the  use  of  treatment-  and  containment-based
remedies.

     23.9  Remedial Design/Remedial Action

     The  selected remedy  for a site  is refined  and specified in the remedial
design (RD)  phase of the process.  Once designed,  the project is let for bids
and the selected contractor implements  the project.  At Fund-financed sites, EPA
funds 90 percent of the costs  of constructing  the  selected remedy, including on-
site or off-site treatment to restore ground-water or  surface-water  quality for
up  to  ten years.   At  sites  where  the State or a political  subdivision was
responsible  for  operation  of  the facility,  EPA's contribution to  the  cost of
construction may be 50 percent or less.

     Progress in Fiscal Year 1987

     As of October 1986, 77 Fund-financed remedial design projects and 54 Fund-
financed  remedial  actions  had been started.  An  additional 39 remedial design
projects and 27 remedial actions  were started by  PRPs  over  the same  period.  In
FY87, another  70 Fund-financed remedial design projects and 35 remedial actions
were started.  Exhibit  2.3-9  shows that 57 of  the  Fund-financed  remedial designs
and  25  of the remedial actions  were   first  starts.    Potentially   responsible
parties started  24 remedial design  projects  and 19 remedial actions  in FY87.
Nineteen of the PRP-financed remedial design projects and  16 of the PRP-financed
remedial  actions were  first  starts.   Sixty-eight administrative  orders  for
remedial  action  also were  issued.   Exhibit 2.3-10 shows the annual number of
Fund-financed  and PRP-financed remedial  design  projects and remedial actions
(RAs) started  from FY80 through FY87.

     EPA  also laid  the groundwork for  future  increases  in  the  design  and
construction  program.    In  this  effort,  Design  and  Construction Management
Workshops were held for Regional  and State personnel.  Revisions to  contracting
procedures (such as the ARCS system discussed in  Chapter 5  of this Report) were
made to improve design  and  construction program efficiency.  EPA also worked with
the U.S. Army  Corps of Engineers  and the Department of the  Interior, Bureau of
                                       40

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
                                    Exhibit 2.3-8
         Historical Data On Remedies Selected in Records of Decision
Treatment-Based Containment-Based
Fiscal
Year
1987
1986
1985
1982-84
These remedies
treatment, using
Source Control
Remedies
33%
32%
18%
11%
Source Control
Remedies
25%
39%
61%
57%
include providing alternative water supplies, conducting only
institutional controls, and also no further action decisions.
Non-Source-
Control
Remedies*
41%
29%
21%
32%
ground-water
Reclamation  to  establish programs with those agencies that will better meet the
needs of expanding  Superfund construction program goals.

     23.10  Operation and Maintenance

     As  of October  1987, a  total of  12  sites had  entered the  operation and
maintenance  (O&M)  phase.  Five of these  sites  entered the O&M phase  in FY87.
O&M commences at a  site  after construction of the remedial action is completed.
O&M activities may include collection and  treatment of ground water or leachate,
maintenance  of water  monitoring  units,  and  overall  site  upkeep.   For  Fund-
financed actions, the Fund pays up to 90 percent of the costs of such activities
for the first year  after an action is  implemented to  ensure that  the remedy is
operational.  The  State  pays the remaining 10 percent.  At  sites  where a State
or political subdivision was  responsible  for operation of  the  facility,  EPA's
contribution to the cost  of operation and maintenance may be 50 percent or less.
After the  first year, however,  all O&M costs are paid by States.

     23.11  Deletion of Facilities

     The Agency has  established procedures  for deleting   from  the  National
Priorities List those sites where conditions no longer threaten human health and
the environment.   After  remedial work  is  completed  at the site,  a  site may be
deleted following public comment, review by EPA Regional and Headquarters staff,
                                       41

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                     Progress Toward Implementing Superfund:  Fiscal Year 1987
      (0
   o c
   *- o
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      75
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                                             42

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                  Progress Toward Implementing Superfund:  Fiscal Year 1987
                             Exhibit 2.3-10
       Historical Superfund Program Remedial Design
                    and Remedial  Action Starts
Remedial   60-
 IPRP*
  Financed

 | Fund
  Financed

  Total
                       1982
              1983    1984    1985    1986
                                      1987
0


5


5
0


4


4
 5


 7


12
 5


16


21
10


19


29
19


26


45
24


70


94
                                      Total
 63


147


210
Remedial
Action      30-
Starts
 JPRP*
  Financed

 | Fund
  Financed

  Total
0


0


0
                      1982   1983   1984    1985    1986    1987
0


9


9
 2


 9


11
 9


16


25
 7


 8


15
12


21
19


35


54
                                                     Total
 46


 89


135
*PRP = potentially responsible party.

Source: SCAP/Remedial Project Pipeline - National Summary Report (1/25/88).

Note: Data are for actions at NPL sites, Including first and subsequent starts. Fund-financed activities Include
program and Fund enforcement actions.  Non-NPL and Federal facilities activities are not Included.
                                      43

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


and State  concurrence.   EPA then  publishes the deletion  decision  in the Federal
Register.   Sites deleted from  the  NPL remain eligible  for Fund-financed remedial
action should conditions  at  the  site warrant such action.

     A notice of  intent  to delete three sites was  published in the Federal Register
in September  1987.   As of the end of FY87, a total  of  thirteen sites had been
deleted from the NPL, eight  in FY86 and five in FY82.

     23.12  State Assurance of Capacity

     Section  104(c)(9)  of CERCLA  requires  that a State  assure the Agency that
it has sufficient capacity for hazardous waste treatment or disposal for a period
of 20 years  following the date  on which EPA and the  State  enter a contract or
cooperative agreement.   For Fund-financed  remedial  actions,  assurances must be
made by October  1989 or  Superfund response action  funding may be withheld.  In
FY87, EPA  awarded a  grant  for $1,200,000 to the National Governors' Association
to develop State-recommended  guidance  on  this  issue by November 1988.   The
Association's recommendations are  expected  to  serve as the basis  for EPA's final
guidance on State capacity assurance.

     23.13  Additional Enforcement Activities

     The enforcement program accomplishments discussed thus  far  in this chapter
are complemented by  significant  additional work  finalized since the passage of
SARA and other ongoing efforts.

     23.13.1 Negotiated  Settlements

     A fundamental  goal of  the  enforcement  program is  to  negotiate voluntary
settlements  on  cleanup responsibilities  as early  as possible.  EPA,  in FY87,
negotiated a  significant number of settlements related  to  cleanup activities:
RI/FS settlements worth $48,000,000 and RD and RA settlements worth $112,000,000.
Also, since  the  passage  of  SARA,  EPA  has  continued  to develop a number of new
mechanisms  to  facilitate  and expedite the  settlement process.  These include
special notice letters, nonbinding allocations of responsibility (NBARs), mixed
funding settlements,  de minimis settlements, covenants not  to sue, and arbitration.
Each of these mechanisms  is  discussed in turn below.

     Progress in Fiscal Year 1987

     In February 1987, EPA issued interim guidance on  streamlining the settlement
decision process.    The  Agency  has  also issued  guidelines  for  expediting the
settlement process.   The guidance describes modifications that will strengthen
and streamline settlement  decisionmaking efforts in the following arejas:

     •     Negotiation Preparation.  EPA will strengthen its negotiating
           position with a  more comprehensive preparation period.  The
           Agency will  undertake  detailed PRP  searches earlier in the
           remedial   process,  conduct  more   complete  exchanges  of
           information,  initiate  discussions  with PRPs at an earlier
                                       44

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                 Progress Toward Implementing Super-fund:  Fiscal Year 1987


          date,  and  prepare  a negotiation  strategy  and   a  draft
          settlement document.

     •    Management Review of Settlement Decisions.   EPA established
          teams  to  conduct  negotiations  and  raise  issues  to  the
          Regional  Administrators  and,  where  necessary,   to  the
          Settlement Decision Committee (SDC).  The SDC consists of the
          Director  of  the  Office  of  Waste  Programs  Enforcement
          (Chairman), Associate Enforcement Counsel-Waste,  Chief of the
          Environmental  Enforcement  Section  at  the  Department  of
          Justice,  and  two   Regional representatives.    While  EPA
          develops  guidance  material  and gains experience with this
          approach, the SDC will review and oversee certain settlement
          issues.  Regional Administrators will eventually assume broad
          authority for negotiation decisions.

     •    Deadline Management.  EPA recognizes that circumstances arise
          requiring  extension  of  negotiations  beyond  the  30-day
          moratorium.  Guidance discourages negotiation extensions, but
          Regional Administrators may  grant extensions of up to 30 days
          when they believe settlement is  imminent.  Further extension
          of RD/RA negotiation beyond  the 30-day period may be  approved
          only by EPA Headquarters.

     Notice Procedures

     CERCLA promotes  negotiations  between EPA  and private  parties  through the
use of notice letters. Notice  letters inform PRPs of their potential liability,
initiate a  continuing exchange of information, and provide  an opportunity for
PRPs to enter into negotiations to conduct or finance response activities.

     In the fourth quarter of FY 1987, 42  special notice letters were issued (31
RI/FS and 11 RA).  On October 19, 1987, the Office of Waste Programs Enforcement
issued  "Interim  Guidance on  Notice  Letters, Negotiations, and  Information
Exchange" (OSWER Directive Number 9834.10).

     The notice procedure is  a three-step process.  General notice is issued to
PRPs  early  in  the  process  of  addressing a  site,  preferably  when a  site  is
proposed for inclusion on the NPL.   It informs PRPs of their potential liability
for  future  response  costs,  promotes  information  exchange,   and  initiates the
process of "informal" negotiations.

     At its discretion, EPA  may  initiate  the second  step  of the notice process
by issuing the RI/FS special  notice.  The RI/FS special notice is sent to a PRP
no later than 90 days  prior to the scheduled start of  the RI/FS.  This procedure,
routinely followed  by EPA, invokes a moratorium on  EPA's  RI/FS  activities and
triggers a period of formal negotiation.   The final step of the notice process,
the RA special  notice,  similarly begins  a period of  negotiation  and invokes a
moratorium on the Agency's RA activities.   For both RI/FS and RA special notices,
the moratoria provide private parties  with the opportunity  to  develop and submit
a proposal to conduct or  finance response activities.
                                       45

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                 Progress Toward Implementing Superfund: Fiscal Year 1987
     Nonbinding Allocations of Responsibility

     As mandated  by CERCLA, EPA has  developed NEAR guidelines.   These  interim
guidelines were  published  in  the  Federal Register on May 28,  1987 (52 FR  19919).
Nonbinding Allocations  of  Responsibility are  notices  sent  to PRPs under  the
authority of CERCLA section 122(e)(3)  informing them of  the percentage  of total
response  costs  at a  facility that  EPA considers  to  be their  responsibility.
Major factors considered in determining response cost allocations are the volume,
toxicity, and mobility of waste and the nature of the case against the different
parties.  EPA will issue NBARs  (normally  during the RI/FS)  at its discretion if
they are  likely  to promote settlement.   NBARs  are  not  a statement of  harm or
causation nor are they admissible as  evidence.   After receiving an NBAR,  PRPs may
offer to undertake or finance  a cleanup; they are expected to determine the final
allocation toward settlement  among themselves.

     Mixed Funding

     CERCLA section 122(b)  provides  explicit  authority for  mixed funding, which
is the use of both  private and Fund resources  to finance response actions at a
single site.  Mixed funding results  from the need for an  expeditious  cleanup.
EPA's evaluation  involves  determining both the most effective  means  of  cleanup
and the most efficient use  of  the Agency's resources.  The  limited contribution
of waste by a PRP and financial weakness are  two factors that  may indicate the
appropriateness  of mixed  funding.   Mixed  funding is best used  in  situations
involving  a  small  Fund share,  and  where there exists  a  strong  case  against
nonsettlors that enables EPA  to  recover its expenditures  from other PRPs.

     On March  14, 1988  (53 FR  8279),  EPA issued  guidance that  discusses  the
factors that are considered in determining whether  mixed  funding is appropriate
for a  given site.   Mixed  funding  can be  accomplished  through  pre-authorized
claims  against  the  Fund and  through  "cash  outs"   or  "mixed work."    EPA  has
approved three preauthorized  PRP settlements   for response  actions  to date:   79
percent of $44,800,000 ($35,000,000), 75 percent of $3,000,000 ($2,250,000), and
66  percent   of   $10,000,000   ($6,600,000),   and  several  others   are  under
consideration.

     De Minimis Settlements

     Section 122(g)  authorizes EPA to enter  into expedited settlements  with de
minimis parties provided that the settlement is  in the public  interest and involves
a minor portion  of the response costs  at the facility.   Two types of  de minimis
parties  are  defined  by  this  section:   de minimis  contributors  (generators  and
transporters)  and de minimis landowners.   A  party may  qualify  as a de minimis
contributor when the amounts and toxicity of hazardous substances contributed by
that party are  minimal  in comparison  to other  hazardous  substances   at  the
facility.   A  de minimis  landowner is  one who did  not  conduct  or permit  the
generation,  transportation, storage,  treatment, or  disposal of  any hazardous
substance at the facility.  In addition, the landowner must not have contributed
to the release or threatened  release at the facility.
                                       46

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     Parties qualifying for a de minimis settlement may be provided with a covenant
not to sue.   Settlements  may be embodied in a consent decree  or  administrative
order.   Parties  who  enter  settlements under  this provision  are entitled  to
contribution protection.

     In FY87, there was one de minimis  settlement for  a value of $340,000 at a site
requiring a $2,500,000 remedy and involving  $5,500,000 of past costs.  The Agency
issued guidance on settlements with de minimis waste contributors on June 19, 1987.
This guidance was published in the Federal Register at  52 FR 24333  (June  30,  1987).
The Agency is presently applying the guidance on de minimis contributor  settlement
at several sites.

     Covenants Not To Sue

     Section  122(f)(l)  authorizes  EPA to issue  a  covenant not to  sue  to
responsible  parties  for   any  liability  to  the United  States  under  CERCLA,
including  future  liability, resulting  from a release or  a threatened  release
addressed by  a  remedial action.    Such  covenants can be  used if:   the covenant
is in  the  public interest;  it would expedite the  response;  the settlor  is  in
full compliance with  a consent decree  under section 106 addressing the  release
or threatened release; and EPA has approved the  response action.

     Interim  guidance on  the  use of covenants  not to sue,  including a  model
covenant,  was issued  on  July 10,  1987 (52  FR 28038,  July 27,  1987).    This
guidance covers the implementation of the mandatory and discretionary  provisions
of section 122(f)  of  CERCLA relating to use  of  covenants.   When  all  necessary
conditions are met, EPA may provide  a covenant not  to sue, but  the covenant may
not take effect until  EPA certifies that the remedial action has been  completed.

     Arbitration

     Section  122(h)(2)   of  CERCLA,   as   amended   by  SARA,  authorizes  the
Administrator, as well as  the  head of any other  department or  agency  authorized
to undertake  a  response action under CERCLA,  to use arbitration as a  method  of
settling section 107 cost recovery claims where the total response costs for the
facility concerned do not  exceed  $500,000,  excluding  interest.  Arbitration may
be used in accordance  with regulations  promulgated by EPA, or  other  authorized
agencies or departments, after consultation with the Attorney  General.

     EPA has  begun  to develop a  regulation that will establish and  govern the
procedures by which EPA may use binding  arbitration as a method of settling cost
recovery claims.  The  regulation will  establish procedures for the referral  of
claims for arbitration, selection and jurisdiction of the arbitrator,  conduct  of
the pre-hearing conference  and  arbitral  hearing,  rendering  of  the  arbitral
decision, appeals from and enforcement  of the arbitral decision,  and  fees.

     23.132 Civil and Criminal Litigation

     Section 103(a)  requires a person in charge of a vessel or facility to notify
immediately the NRC as soon as  he  or  she has knowledge of any release,  other than
a federally permitted release, of a hazardous substance in  an amount equal to  or
                                       47

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


greater  than a  reportable  quantity.   Criminal  sanctions  may  be  imposed  for
failure  to  comply.   The  NRC must  convey  notification expeditiously  to  all
appropriate  agencies, including the Governor of any affected  State.

     Section 103(b)  establishes  a notice  and reporting requirement  for  the
storage, treatment, or  disposal of hazardous substances.  The notice  must  specify
the type and amount of hazardous substances found at the facility, and any known,
suspected,  or  likely releases of  such substances from  the  facility.    Knowing
failure  to  provide  such notice  could result  in  the  imposition  of criminal
sanctions.   In addition, the violator will not be entitled to any limitation of
liability or to any defenses to liability  set out  in section 107 of  the Act.   It
is important to  note, however, that  notice  is not required if  the  facility  has
already  been permitted  or accorded  interim status  under  Subtitle C  of  the
Resource Conservation and Recovery Act  (RCRA).

     Section 103(c)  addresses the failure  to notify  EPA about an  unpermitted
facility at which a hazardous  substance  is treated, stored, or disposed.   Section
103(d) addresses destruction or concealment of records that the Act requires to
be maintained.   Criminal sanctions may be  imposed  for  failure  to comply with  the
requirements of  these subsections.

     SARA  amended CERCLA enforcement  authority  by adding  civil penalties  and
strengthening the existing criminal penalties.  SARA added Class I  and Class II
administrative penalties under section 109  for non-notification concerning  the
release of  a hazardous substance in an  amount equal to or greater than  its RQ.

     Past and Ongoing Criminal Enforcement Activities

     Since  FY  1983,  the EPA's Office  of  Criminal Investigations,   the National
Enforcement  Investigations Center  (NEIC),  has conducted  183 investigations that
have been based in  whole  or  in part  on  suspected violations  of  the criminal
provisions  of  CERCLA.   Of  these  investigations,  136  are closed and 47 remain
active.  To date, approximately 20 investigations  have  resulted  in prosecutorial
action taken pursuant to CERCLA.   These include two cases involving convictions
and one case involving  reversal.  An additional four investigations have  inspired
criminal cases that remain open pending appeal or  further prosecution.  These 24
cases include counts for violations of  section 103(b)  and (c) of the Act.

     Progress in Fiscal Year 1987

     In August 1987,  EPA developed interim guidance on imposing Class I and  Class
II penalties for non-notification concerning releases  of  hazardous substances in
amounts  equal  to or  greater  than  RQs.   These  procedures  will  amend  the
Consolidated Rules of Practice at 40 CFR  Part 22.

     23.133  Enforcement Regulations, Policies, and Guidances

     Since  the passage of SARA, a number of  regulations,  policies, and guidances
have  been  issued or   are  near  completion.    These  documents support  both
enforcement  and  settlement efforts.
                                       48

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     Administrative Record

     CERCLA  section  113(k) requires EPA to establish an administrative  record
for  selecting a response  action.   Regulations  allowing interested parties  to
participate  in  the  development  of  the  administrative record must  also  be
promulgated.  Use of the record achieves two goals:

     •    It allows for increased public  participation in the selection
          of  the response  action.

     •    It  limits the scope of any judicial review to  the available
          record  in  any judicial  action  concerning the adequacy  of
          response action,  thereby minimizing delay and reducing  the
          cost of litigation.

     The Agency  drafted proposed  regulations on  the  administrative record  in
conjunction with  revisions to the  NCP.   The  regulations are subpart  I  of  the
proposed revised NCP.  In May 1987, the Agency issued guidance on the use  of  the
administrative record  in  selecting CERCLA response  actions.  Several  training
sessions, workshops, and Regional visits have been conducted to  ensure  adequate
compilation and maintenance of the administrative record. To date,  most Regions
have compiled administrative records for their high-priority sites.

     Indemnification of Response Action Contractors

     CERCLA  section  119  requires   that  EPA  first publish  guidance,  and then
regulations,  concerning   EPA  indemnification  of  Superfund Response   Action
Contractors  (RACs) working for EPA, States,  or potentially  responsible  parties.
Section  119 also  requires that EPA  guidance be  developed  and that  adequate
opportunity for public  comment be provided.  To assist with guidance development,
EPA has organized an internal Task Force, an external review panel  consisting of
insurance and actuarial experts,  and another external review panel  consisting of
representatives of the RAG  community.

     The   Task  Force   has   distributed   interim   guidelines   and   interim
indemnification contract language  to  EPA contracting officers for use with  EPA
contracts.    Interim guidance has  also  been provided to the Regional Offices
concerning indemnification  of RACs working for States and PRPs,  as  well as more
detailed guidance concerning indemnification of EPA contractors.  Final  guidance
is currently under development and  will be proposed in the Federal Register for  public
comment.  Following the public comment period, final  guidance will  be published.

     All EPA  response  action contracts containing indemnification  clauses have
been modified to reflect the  requirements of section 119.   Pursuant to section
119, several  RACs working  for States  at State-lead NPL sites have  been offered
indemnification by EPA.    To date,  EPA has  not  offered  indemnification  to  any
RACs working for PRPs.
                                       49

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                 Progress Toward Implementing Super-fund:  Fiscal Year 1987


     Supplementary Enforcement Directives

     In addition to the key guidances of the enforcement program discussed above,
OSWER has issued a  number of enforcement-related directives in FY  1987.   These
directives serve to describe  procedures of the enforcement mission and to amplify
CERCLA provisions related to enforcement.

     Procedures pertaining to the early phase of an enforcement action are laid
out in directives that cover access  to a site and provide guidelines for the PRP
search and  off-site response.   Other  directives  describe landowner  liability,
limitations on cost recovery, and the reimbursement of abatement costs.  A final
directive pertains  to changing the  status  of a site  from enforcement  to Fund
lead.

     2.4 Status of Active Remedial  Investigations/Feasibility Studies and Remedial Actions

     This section includes a summary status  report for  all RIs, FSs,  and RAs in
progress as of September 30, 1987,  the end  of  the  fiscal year.   The  detail of
the status report,  required by subparagraph  (B), (C), and (F)  of  GEORGIA section
301(h)(l), is presented in Appendix D.  At the end of FY87,  remedial  activities
were underway at 533  sites.   There were  642 ongoing  remedial  projects:   548
RI/FSs, 15 FSs, and 79  RAs.   The reference date used to determine the status of
the projects  is  January 1,  1987, which, EPA acknowledges,  may not account for
all the time  gained or  lost  in the life cycle of a given project.   However, EPA
chose the date because it marked the first update for RI/FS and RA projects after
the hiatus between Superfund authorizations.  Choosing an earlier date would have
included time  lost due  to circumstances beyond EPA's control.

     To understand what the  status report means, we have included the following
discussion  of the  EPA approach, based on  operable  units,  to  accounting for
cleanup activities  at a Superfund site.  At many  Superfund sites, a number of
remedial activities* may be needed because,  in addition to a discrete source of
contamination,  soil,   ground  water,   air,   or  surface  water  also  may  be
contaminated.  Remedying this  degree of contamination  is often a complex task,
requiring health and  environmental risk assessment and  painstaking  design of an
engineered solution.

     Operable Units

     To  handle complex problems efficiently,  the needed site  work  is  often
divided into  several  distinct  activities  or "operable  units"  that  take form at
the  start  of or during an  RI/FS.   One operable  unit  may begin and end at a
different point  in  time from another,  depending on a variety  of  factors.   Most
operable units  are  specific  to a group of activities intended to mitigate some
part of the threat  to human  health or  the environment posed by the  site.
       Investigations and studies done to determine  the  extent  of a release,
although included  in the statutory  definition of removal activities Ln CERCLA
section 101(23) by reference  to  section  104(b),  are  commonly considered
components of the  remedial program  and are  treated as such in this Report.


                                       50

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                 Progress Toward Implementing Superfund: Fiscal Year 1987
     The first operable  unit is referred to as the first start;  operable  units
that follow  are  referred to as subsequent starts.   The first operable  unit  may
involve replacing a water  supply;  a  second  operable unit may control  the spread
of contamination from an abandoned municipal waste landfill and  the  associated
plume of ground-water  contaminants that  is  flowing toward a public  water supply
wellfield.

     The operable unit approach enables  EPA to effectively set  priorities  for
site cleanup  and manage  the project  overall.  After the remedy for an  operable
unit is selected in  a ROD, the RD phase usually follows, and then  construction
of the RA begins. Many events  influence  the progress of an operable  unit through
the Superfund system.  The more significant influences  include:

     (1)  Changes in the entity primarily responsible  for the project,
          which can be EPA, a State,  or a potentially responsible party
          or  parties;

     (2)  Changes in  the number of operable units underway  at a site;
          operable units are sometimes consolidated or expanded due  to
          new information  or changes in  circumstances;  and

     (3)  Complex contracting  arrangements  involving  EPA, the States,
          potentially  responsible parties,  and the  availability  of
          response action  contractors.

     EPA's system for tracking the status of RI/FSs,  FSs,  and RAs, illustrated
in Appendix D, reflects the operable unit approach by  including the  RI/FSs, FSs,
and RAs for  each operable  unit at a site.  Numbers illustrating  project status
are  presented  in  Exhibit  2.4-1;  project  totals  by  Region  and  State  are
illustrated  in Exhibit 2.4-2.

     2.4.1  Status of Remedial Investigations and Feasibility Studies

     Of the  563  combined RI/FS and FS projects, 48 (8.5 percent) were  ahead of
schedule, and 148 (26.3 percent) were  on schedule.  Approximately 57  percent of
RI/FS and FS  projects  were behind schedule  at the end of the fiscal  year:   280
(49.7 percent)  of the RI/FSs  were  1 to 4 quarters  behind schedule;  35 (6.2
percent) were 5 to  8 quarters  behind;  and  8  (1.4  percent)  were  more than  8
quarters behind.  No  estimates of  completion for the  remaining 44 (7.8  percent)
had been made prior to the estimates made at  the end  of the fiscal  year.   Thus,
there is no basis of  comparison for  these projects.

     Project  delays  can  be attributed to many factors  including the hiatus  in
program funding  during the FY85-FY86 period; the necessity to complete complex
contracting  arrangements  before  projects  could  begin; and  a high  level  EPA
employee turnover.   The Agency's goal is  to  complete an RI/FS and  select  a remedy
within 18 to 21 months. Historically,  however, RI/FSs have taken 24  to 35 months
to complete.
                                       51

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                  Progress Toward Implementing Superfund:  Fiscal Year 1987
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                                           52

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      Progress Toward Implementing Superfund:  Fiscal Year 1987
                       Exhibit 2.4-2
      Remedial Investigation/Feasibility Study and
      Remedial Action Projects in Progress at the
          End of Fiscal  1987 by Region/State
Region
State
RI/FSs
FSs
RAs
Sites
Region 1






Region 2



Region 3





Region 4








Region 5





Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Total
New Jersey
New York
Puerto Rico
Total
Delaware
Maryland
Pennsylvania
Virginia
West Virginia
Total
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Total
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
3
4
19
7
5
1
39
52
41
5
98
3
4
37
8
3
55
7
13
1
4
2
8
6
3
44
16
15
37
19
20
17
Total 124
0
0
2
0
0
0
2
2
0
0
2
0
0
0
1
0
1
0
1
0
0
0
0
0
0
1
0
0
0
0
0
0
0
3
1
3
1
1
0
9
3
12
0
15
0
0
8
1
1
10
0
1
0
0
0
0
0
0
1
1
3
5
7
1
1
18
4
5
15
7
5
1
37
56
39
5
100
3
4
41
9
4
61
7
15
1
4
2
8
6
3
46
14
17
37
16
21
18
123
                            53

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      Progress Toward Implementing Superfund: Fiscal Year 1987
                        Exhibit 2.4-2
                        (continued)
      Remedial Investigation/Feasibility Study and
      Remedial Action Projects in Progress at the
          End of Fiscal 1987 by Region/State
Region
State
RI/FSs
FSs
RAs
Sites
Region 6





Region 7




Region 8






Region 9



Region 10



Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Total
Iowa
Kansas
Missouri
Nebraska
Total
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Total
Arizona
California
Guam
Total
Idaho
Oregon
Washington
Total
5
2
7
3
20
37
7
6
13
_6
32
9
18
1
0
6
1
35
8
52
1
61
4
4
15
23
0
0
0
0
1
1
0
0
1
0
1
2
1
0
1
0
0
4
0
3
0
3
0
0
_Q
0
1
2
0
0
_3
6
2
0
4
1
7
1
0
0
0
0
0
1
0
7
0
7
0
1
4
5
6
4
4
3
20
37
8
4
11
4
27
8
5
1
1
6
1
22
6
51
1
58
3
5
14
22
Total All Regions
          548
           15
           79
           533
                             54

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


     RI/FS Initiatives

     The  Agency  has  initiated several  activities  directed specifically  toward
acceleration of  RI/FS  projects.   A key step,  the RI/FS Improvement  Initiative,
includes planning, priority-setting, use of operable units, and streamlining  of
the RI/FS process.  RI/FS streamlining focuses on tailoring the scope and  detail
of the RI/FS  to  site conditions.  The  analysis  of evaluation criteria and the
development of a range of  remedial  alternatives will be  better  suited  to the
complexity of the problems at  the  site.  Fewer alternatives will be developed for
sites with straight-forward problems, and clearly  impractical  alternatives will
not be studied in detail.

     OERR revised RI/FS  guidance  to  reflect  the  new emphasis  and provisions  of
CERCLA,  incorporate aspects  of  new or  revised  guidance related  to RI/FSs,
incorporate management initiatives designed to streamline  the  RI/FS process, and
take advantage of experience from previous RI/FS projects,  where  appropriate.

     2.42  Status of Remedial Actions

     Of the 79 ongoing RA projects,  13 (16.5  percent)  were ahead of  schedule;
24 (30.4  percent) were on schedule.   A total  of  31 (39.2 percent)  RA projects
were behind schedule:   26 (32.9  percent)  were 1  to 4 quarters behind  schedule;
4 (5.1 percent)  were 5  to 8 quarters behind;  and 1 (1.3 percent) was  more than
8 quarters behind.   For  the  remaining 11 (13.9 percent),  there  were no prior
estimates of completion.

     RA Initiatives

     A  key  initiative  is  OSWER's   Strategy  for  Management   Oversight  of the
Remedial  Action  Start  Mandate.   Although directed primarily  toward  satisfying
CERCLA's new mandate for RA starts,  it also establishes a  Headquarters-Regional
management plan that incorporates principles  that will  be  applied  throughout the
program   to   accelerate  the   response  process.    Using  current   Superfund
Comprehensive Accomplishments Plan  (SCAP)/Strategic  Planning  and  Management
System (SPMS) accountability  systems,  the Agency will  focus attention on early
portions  of project schedules to  identify  projects that  could  slip  or  issues
that could affect project schedules,  such  as State  cost assurances, site access,
disposal  capacity,  or  property  acquisition.    The program will also use the
upgraded CERCLIS and the Office of Enforcement and Compliance  Monitoring  (OECM)
docket to track  the  progress  of each project  and  develop exception reports  on
projects that are behind schedule.  Appropriate assistance  can then  be provided
to keep projects on schedule.

     Also, OERR  is developing model  design schedules based on  Agency experience
with a variety of remedial  alternatives.  Model  schedules will assist Remedial
Project Managers  in preparing  accurate  site-specific schedules  and action  plans.
Another important  step was the  development  of the project management concept
under which  the  program  will  emphasize the  importance  of involving only one
contractor in  all phases  of  the response.    OERR is  implementing  the single-
contractor concept  through ARCS,  which will  award numerous remedial  contracts
in a Region or group of Regions.  ARCS will  promote  continuity of  performance
                                       55

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


from RI/FS  through construction management,  increase competition  for  remedial
contract  awards,  and facilitate  the  delegation of  contract management  to  the
Regions.   Regions  will  be able  to   pinpoint  and  assign  additional  work  to
contractors doing quality work  on  schedule.

     In addition, OERR  is considering  a  construction management support program
that would  make a  construction management specialist  available to  assist  the
Regions in planning and executing RDs and RAs.   OERR is also  negotiating  with
the Corps of Engineers and the Bureau  of Reclamation about their role in meeting
program objectives.  Negotiations are focused on working closely with the Regions
and establishing faster contracting procedures for  assigned RDs and RAs.

     2.43  Initiatives to Meet Schedules

     During  FY87,  the  Agency  developed  a  multiple-initiative  strategy  to
accelerate RI/FS and RA activities  and  meet schedules  for RI/FS and RA initiation
and completion.  The objectives  of the strategy are  to improve  EPA's ability to
estimate the duration of projects, to  complete projects on schedule, and to  meet
the additional responsibilities imposed by amendments to CERCLA that require EPA
to begin 175 first-start  RA projects by  October 16,  1989,  and an additional 200
by October 16, 1991.

     Enforcement Initiatives

     The enforcement program is working to expedite  processes such as settlement
negotiations that may  delay response  actions.   Negotiations will be tracked to
ensure compliance with  guidance on streamlining the  CERCLA  settlement  process.
Also,  special  notice   guidance  has been completed requiring  that moratoria
imposition coincide with release of the FS and proposed plan in order to  minimize
delays in remedy implementation after  the ROD is  signed.

     Regional Initiatives

     Regional  initiatives include  the  insertion of  schedules in all cooperative
agreements,  interagency  agreements, contracts,  work assignments,   and  consent
decrees to ensure  that  EPA  will meet  scheduled targets.  In  addition,  to avoid
slippage  in  the initiation of  remedial construction,  the Regions  may  subject
remedial designs to review  for  bidability, construetability,  and operability.


   2.5 Status of Facility Reviews Under CERCLA Section 121 (c)

     Section 301(h)(l)(E) of CERCLA requires a report on the progress  made in
reducing  the  number of facilities (or sites)  subject to periodic  review under
section 121(c) .  In addition to satisfying the  section 301(h)(l)(E)  requirement,
this Report satisfies other and similar requirements in section 121(c) to report
to Congress:   (1)  a list of facilities  for which such review  is  required;  (2)
the results of all  such reviews; and   (3) any actions taken  as  a result of  such
reviews.  The  available information on section 301(h)(l)(E)  and section 121(c)
requirements  is  included in this  Report,  and will  be augmented in subsequent
reports as section  121(c) implementation proceeds.
                                       56

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


     Section 121(c) of  CERCLA requires a 5-year review of those sites at which
hazardous substances,  pollutants,  or contaminants remain at a site after remedial
action has been  initiated.   It is  further  stipulated that if the results of a
review indicate  further action is  necessary,  the  appropriate action should be
taken.  The Agency proposed a policy,  in the revisions to  the NCP, for defining
the sites where  reviews  must  be conducted and describing the purpose of the 5-
year reviews.  The application of  this policy (summarized in  section  2.5.1) will
be affected  by the progress  made  in implementing remedies  that adhere to the
cleanup standards specified in section  121.

     2.5.1  Facilities Subject to Review

     Selected  remedial  actions  permit hazardous  substances,   pollutants,  or
contaminants to  remain  on site when they  do not  threaten human health or the
environment.  However, if the concentration of contaminants left on site exceeds
established levels, EPA  is proposing to conduct a  facility review  to ensure the
remedy continues  to be  protective  of human health and  the  environment.   This
approach is  consistent  with clean  closure  under  the  Resource Conservation and
Recovery Act.  Reviews  will be  conducted at sites currently considered to have
"safe" levels  of contaminants if  and when standards defining protective levels
are changed  such that  these  sites  are  considered to have  "unsafe" levels of
contamination.

     If a review shows that a remedy is no  longer protective,  additional actions
shall be taken to mitigate the threat.  Sites will become  subject  to the review
process and enter the inventory upon completion of the remedial action.  Sites
deleted from the NPL  will still be  eligible  for  review.   Facility reviews are
not planned  to be conducted  at non-NPL sites where  removal actions have been
undertaken.

     Once EPA  finalizes the policy  for  implementing  section 121(c), operating
procedures will be established for:

     •    Tracking site status,  including quantity of  wastes  remaining
          on site,  occurrence of releases,  integrity of  containment
          or other remedial measures,  and need for  further remediation;

     •    Re-examining  site  status,  including  potential  application
          of newly  developed treatment  technologies,  and procedures
          to initiate new remedial  action;  and

     •    Collecting information on site  status and reporting to  EPA
          managers and Congress.

     Procedures also will  be  established for determining  the progress  made in
reducing the  number  of facilities  subject  to review  under  section  121(c).
Progress in this area will be a function of  increases  in selection of source-
control remedies that include treatment.
                                       57

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                Progress Toward Implementing Superfund:  Fiscal Year 1987
                                        Exhibit 2.5-1
                Facilities  Subject to CERCLA Section  121(c)*
Region
State
Site Name
Status
2
3
3
3
4
4
4
5
5
5
9
9
9
New Jersey
Maryland
Pennsylvania
Pennsylvania
Georgia
Mississippi
North Carolina
Michigan
Minnesota
Ohio
American Samoa
Saipan
Trust Territory
of Pacific Islands
Friedman Property
Chemical Metals Industries,
Inc.
Enterprise Avenue
Lehigh Electric and
Engineering Co.
Luminous Processes, Inc.
Walcott Chemical Co.
Warehouses
PCB Spills
Gratiot County Golf Course
Morris Arsenic Dump
Chemical and Minerals
Reclamation
Taputimu Farm
PCB Warehouse
PCB Wastes
Deleted from NPL
Deleted from NPL
Deleted from NPL
Deleted from NPL
Deleted from NPL
Deleted from NPL
Deleted from NPL
Deleted from NPL
Deleted from NPL
Deleted from NPL
Deleted from NPL
Deleted from NPL
Deleted from NPL
'The final list of sites that are subject to 121(c) review is still being developed. This list currently includes only sites
that have been deleted from the NPL and that potentially are subject to section 12l(c) review.  Other sites potentially
subject to review, including sites where operation and maintenance has commenced, are being considered for inclusion.
                                              58

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     2,5.2  List of Facilities Subject to Review

     Facilities  potentially subject to  review  under section 121(c)  are  listed
in Exhibit 2.5-1.   The  list now includes sites  that have been  deleted from the
NPL.  A review is being conducted to determine at which of these sites remaining
contaminants  exceed health-based levels.   EPA  also will review sites  at which
remedial action  or  operation and maintenance  has started for possible inclusion
on the section 121(c) list.

     2.6 The Cost Recovery Program Under CERCLA Section 107

     During the fiscal year, EPA Regional offices referred 37 cost recovery cases
with a  combined dollar value of $30,592,354 to EPA  Headquarters.   A  total  of
$18,866,000 was  collected and deposited  in  the  CERCLA Trust  Fund.   Exhibit 2.6-
1 illustrates the key results  of the cost recovery program  prior to  and  during
FY87,  and  also  includes  the number of  actions referred  to the Department  of
Justice  (DOJ),   actions  filed   by  DOJ,  and  the   dollar  amounts  the actions
represent.

     Through  the end  of FY87, EPA had  initiated actions  to recover  $242,000,000
worth of costs  incurred at 158 sites and  had  collected $48,598,000.  Exhibit
2.6-2 illustrates the value of  cost recovery settlements for each  fiscal year.
During FY88,  EPA expects  to initiate 49 additional cost recovery actions worth
approximately $118,000,000.

     EPA's object  in the cost  recovery program is  to pursue  reimbursement  in
every case where there  is  a financially viable PRP.   The liability  imposed  on
PRPs by CERCLA section 107 enables  EPA  to begin  response action at a  site without
waiting for  the outcome of a  legal action.    In this way,  the program  allows
response action  to  go forward and  conserves  Superfund dollars.

     During   the  pre-remedial   investigation,   parties  identified   as   being
responsible for  the threat  posed by  a  site  are  given  the  opportunity  to design,
construct,  and fund cleanup action.  The PRPs,  which  may  include generators and
transporters  of the  hazardous  substances  involved  in the  release  as well  as
current and former  owners or operators of the site, must  agree  to reimburse EPA
before the start of the RI/FS.

     If PRPs  initially refuse to pay for site cleanup, EPA can  proceed with the
necessary response actions  and subsequently sue the PRPs  to recovery costs.  EPA
can also,  under  CERCLA  section  104,  recover  the costs of third-party oversight
activities, which are incurred when  EPA  contractors assist EPA  in the oversight
of  PRP  cleanup  activity.   For example,  EPA  contractors  may  oversee   field
activities, such as  sampling.  The Agency can  sue PRPs or  recover oversight costs
by administrative order or  consent decree.
                                       59

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                    Progress Toward Implementing Superfund: Fiscal Year 1987





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   Progress Toward Implementing Superfund:  Fiscal Year 1987

                       Exhibit 2.6-2
Value of Cost Recovery Settlements by Fiscal  Year
     Fiscal Year               Total Dollars Recovered


       1987                      $35,755,000

       1986                       17,300,000

       1985                       18,000,000

       1984                        7,000,000

       1983                        2,000,000

       1982                        3,000,000

       1981                          250,000
       Total                      $83,305,000
                            61

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


3.0   THE FEDERAL-STATE PARTNERSHIP IN IMPLEMENTING CERCLA

     3.1 Overview

     The  original  CERCLA  enacted  in  1980  provided  for  State  involvement in
response activities by allowing EPA  to enter  into  cooperative agreements (CAs)
with States to undertake  Fund-financed  response activities.  CERCLA, as amended,
extended  this opportunity  to  Indian  Tribes  and  political   subdivisions  and
included enforcement in the definition of response.

     EPA may enter into CAs with States or political subdivisions of States, or
Indian Tribes which:  (1) allow a State to take the lead in response activities
at a single site or at several  sites in  the State;  (2)  allow EPA and the State
to take the lead for different response activities at a site or number of sites
in the State; and  (3)  provide funding  for States  to assist  or support EPA-lead
response  actions.   In addition,  EPA  uses  Superfund  State contracts  to gain
assurances regarding shares of response costs  for which States are responsible,
and State operation and maintenance obligations at EPA-lead sites.

     The Agency  has developed guidance for entering  into CAs  with States that
enable the States  to take  the lead on  Fund-financed pre-remedial response (PAs
and Sis),  remedial response  (RI/FSs,  RDs and RAs),  removals,  and enforcement
activities.  EPA  has also developed guidance for CAs with political subdivisions.
CERCLA provides for Indian involvement in the  Act's implementation by requiring
that  Indian  Tribes be  treated  substantially  the  same  as  States,  and  by
authorizing EPA to enter  into CAs with  Indian Tribes  in order that they may take
the lead for CERCLA response.

     Federal agreements with States  to conduct remedial  actions  also have been
affected by CERCLA section 104(c)(9).   Beginning in  1989,  a  State must assure
EPA that  adequate capacity  exists  for  the destruction,  treatment,  or secure
dispostion of  all  hazardous waste expected to be generated within  the State.
The assurance must be made for the 20-year period following the signing of a CA
with a State;  EPA provides this assurance  for agreements involving Indian Tribes.

     SARA  emphasizes   the  CERCLA provisions  concerning  State  involvement  by
requiring  "substantial and  meaningful"   State  involvement  in  all  phases  of
response activities.   Specifically,  the  passage of  SARA  required the Agency to
undertake  several  initiatives,  including promulgation of procedures  for State
involvement under  CERCLA  section  121(f), and the  identification of applicable
or  relevant   and   appropriate   requirements   (ARARs)   in   the   Federal-State
partnership.

     Finally,  CERCLA  requires  that  EPA  develop  and  implement procedures  to
adequately notify  concerned State and local  officials  of  limitations  on the
payment of claims  for CERCLA response costs.
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     3.2  Progress in Fiscal Year 1987

     EPA's  FY87 achievements  in the area  of State participation  in Superfund
consisted  of the planning  and  implementation of CERCLA-mandated measures,  and
the enhancement of  these  measures by several additional EPA initiatives.

     32.1 Oversight Policy

     Increased  State  involvement in hazardous substances response will require,
in some instances, changes in EPA's oversight role and more flexibility in Agency
oversight  of State  implementation  of  CERCLA and  State-lead activities.   The
Agency is  developing a comprehensive oversight policy  for State  implementation
of CERCLA  and detailed guidance  on  how to  apply this policy.  The  policy will
address  the following components:  (1) working with  States  to reduce or eliminate
duplication  of Federal  and  State  efforts;   (2)  identifying  weaknesses  and
strengths in State efforts;  (3)  assisting States in improving their capabilities;
(4) helping States  increase their  participation  in  Superfund responses;  (5)
improving  State environmental  programs  to focus  efforts  on tangible  cleanup
results, rather than on financial and accounting work; and (6) ensuring that the
oversight effort corresponds to a State's capability, experience, and role in the
particular response  activity.

     3.2.2 Superfund Memorandum of Agreement

     EPA also  encourages  State  involvement beyond the minimum statutory  and
regulatory requirements through  a Superfund Memorandum of Agreement (SMOA).  The
SMOA is  an agreement between the EPA Regional Administrator and the head of the
relevant State  agency that defines the State's role and EPA's role when each one
acts as  the  lead or  support agency at a hazardous waste site.

     The  SMOA  spells out  processes  for  Federal-State  coordination  on  pre-
remedial, remedial,  and enforcement response activities, and on certain aspects
of  removal  activities.   The SMOA  clarifies roles  and expectations,  thereby
improving  coordination and reducing  misunderstandings.   The SMOA provides  the
opportunity  for all  States,  as their individual capabilities permit,  to become
more active  and undertake greater  responsibility  in response activities.   The
SMOA establishes an annual consultation process in which EPA and the State agency
identify the lead agency for various response activities, set priorities,  and
provide  for  State involvement in long-range planning.   Individual CAs or multi-
site CAs combine with the SMOA to make the Federal-State partnership as  flexible
as possible.

     323 State Involvement Regulations

     Section 121(f) of CERCLA, which was added by SARA,  requires that the Agency
promulgate regulations providing States with an opportunity for  "substantial and
meaningful"  participation in  all aspects  of remedial  response.   CERCLA  also
establishes minimum  statutory requirements  for State  involvement.

     The Agency has developed proposed revisions to the NCP that include CERCLA-
mandated regulations  on  State participation in  the implementation of  the  Act.
Under this proposal, Subpart  F of  the proposed revised  NCP addresses  all issues


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related  to  State  involvement  in hazardous  substance  response.    Subpart  F
delineates State involvement in pre-remedial,  remedial, and enforcement response
in  the  manner required  by CERCLA section 121(f)(l).   The proposed NCP also
defines EPA  involvement  as  a  support  agency  in  State-lead response activities.
The proposed revisions to the NCP were published  in November 1988.

     The Agency provided for significant State participation in the development
of  the  proposed revisions  to  the NCP through  a State  Issues  Reauthorization
Workgroup and through State involvement in  the NCP Workgroup and other Superfund
Implementation  Workgroups.    To  facilitate  State  participation  in  these
Workgroups,  EPA  provided a grant to the National Governors'  Association (NGA)
in  1987 to work  closely  with the State representatives  on the  workgroups,  and
also  with the  Association of  State  and  Territorial  Solid Waste  Management
Officials  (ASTSWMO),  and the  National Association of Attorneys  General  (NAAG)
to assure that all State views were received.

     As part of  this  process,  the NGA staff  liaison  has:   (1)  coordinated the
various  State  concerns   and  conveyed  these  concerns  to EPA;   (2)  provided
information on workgroup  efforts  to ASTSWMO  and NAAG for distribution to their
members;  (3) ensured  that  State  representatives received materials and advance
notice  of   workgroup meetings;   (4)  coordinated   the   selection  of  State
representatives  to serve on newly formed  Superfund  workgroups;  and  (5)  served
as a State liaison between the EPA project officer,  workgroup chairs, and other
appropriate EPA staff and the States.   EPA has provided NGA with a second grant
to continue this work through FY88 and FY89.

     CERCLA, as amended,  requires EPA  to attain  State  ARARs that are promulgated
and are more stringent than Federal ARARs.   Subpart F of the proposed revisions
to  the  NCP requires  Federal-State interaction  on identification  of ARARs  and
will establish an  appropriate process.   In addition,  the  Agency is  developing
procedural  guidance  for  implementing  this requirement  that  will  outline  the
procedures and roles of States and EPA when acting as lead or support agency.

     The  Agency   is   also  developing  specific guidance   on  Federal-State
relationship in  identifying ARARs  to  determine  how  to address "more  stringent"
State standards, particularly under Federal environmental  statutes where  States
either  have  delegation or are otherwise  authorized  to  administer the Federal
programs.  In addition, the Agency is  developing .guidance on how the Agency will
address unique  State  requirements, such as  bans on  landfill  disposal,  siting
requirements, or non-degradation standards.

     The Agency includes requirements for  State credits toward State  cost-share
obligations  in  the revised NCP.    The  Agency has prepared interim guidance on
State credits  and is  improving  Agency financial management  systems to  ensure
proper management and application of State credits.

     The  Agency  is also  providing for State involvement  in the  selection of
remedy  process  that will depend  upon a State's capability and experience,  the
EPA-State  relationship,   and  site-specific   characteristics.    The  Agency  is
developing  comprehensive guidance on the  State  remedy selection process  for
State-lead  sites,  including  the  timing   and  procedures  associated  with  the
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process,  and criteria  to determine  State  eligibility  to  participate in  the
process.

     CERCLA and the State involvement regulations  that are  part  of  the  proposed
changes  to the  NCP  significantly expand  State  involvement in  the  remedial
process.   In  addition to those  elements discussed above,  the remedial process
includes  an annual  planning meeting  at which  the  EPA Region and the  State
identify the lead agency  for a site-specific response, establish priorities  and
schedules,  and  agree on  funding requirements.   The  remedial process  requires
lead agency consultation  with  the "support" agency prior to  publication of  the
proposed plan  and the inclusion of a statement in  the  notice of  the  proposed
plan detailing the support agency's position on the  plan.

     3.2.4  Training

     The Agency  increased its  technical assistance and  training efforts during
the year.   A training course for Cooperative Agreement  Project  Officers at  EPA
and at  State agencies was developed.   The Agency also developed a  construction
management course for the EPA Regional  offices and the States.   The Agency will
continue  to work  with  States   and State  officials'  associations  to  provide
technical assistance to States on how to establish a  program to implement CERCLA
and how to  develop and enhance  State capabilities to participate more  fully in
CERCLA implementation.

     32.5  Notice of Limitations on the Payment of Response Claims

     Section lll(o)  of  CERCLA,  as amended by SARA, provides  that the  President
shall develop and implement procedures  to adequately  notify concerned  local  and
State officials  and  other concerned  persons of limitations  on the payment of
claims  for  necessary  response  costs.   The statute requires that the procedures
be developed no  later than  90  days after  enactment  of  the  CERCLA  amendments.
The notice procedures, once developed,  would be utilized as  soon as  practicable
after a site is included  on the  NPL.

     EPA was  delegated the  responsibility for implementing notice procedures
under CERCLA section  lll(o)  by  January 17,  1987.   Due to time constraints,  and
the link  with  the procedures  for  filing  claims  against the Trust Fund  under
section  112,  EPA  notified  the  public that  section lll(o) and  section  112
procedures would be proposed jointly.

     On February 5,   1987,  EPA  published  in the  Federal Register  a notice titled
"Limitations on Superfund Response  Claims"  (52 FR  3699)  to  advise the  public of
the limitations  on CERCLA  response claims  and  that  adequate opportunity  for
comment would be provided before EPA adopted procedures for  notice  pursuant to
section lll(o) of CERCLA.  EPA's Federal Register notice referred the public to  the
NCP,  at section  300.25(d),  that requires that any person  who takes a  response
action and  intends to  seek reimbursement from  the Fund must  (1) notify EPA  and
(2) obtain EPA's approval  prior  to  undertaking  the  response  action.    EPA's
process of prior approval is known  as "preauthorization."
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     EPA plans  to propose procedures  to  notify persons  of  the limitations  on
response claims (i.e., section lll(o) procedures) and  the procedures for  filing
claims  against  the  Fund  (i.e.,  section  112  procedures)  in  1989.    These
procedures, to  be proposed as 40  CFR  Part  307, will  also  serve to advise  the
public  of   the  requirements  to   be  complied  with   in   order  to   obtain
preauthorization.

     32.6  Other Initiatives

     A  key  stumbling  block  to   increased  State  participation  in   CERCLA
implementation has been the lack of State  capability.   Thus,  EPA is establishing
a core  funding  cooperative agreement.   This  non-site-specific funding vehicle
will  support  State  functions necessary  to implement  CERCLA  and  build State
capability.    Examples  of eligible  funding  categories  are  general  program
management, training,  interagency  coordination, general  legal assistance,   and
fiscal and contract management.  Three  CAs for core programs were funded  in FY87.

     In order  to  involve  States in  the initiation  and development of guidance
on the  remedial process,  the Agency will continue  the State Issues Workgroup,
which will provide a forum for State issues and concerns.

     The Agency is  now developing detailed guidance  on how the State capacity
assurance will be made,  when,  and under what circumstances,  it will be required,
and what States must  do to provide EPA with an adequate assurance.  The  Agency
is also providing technical  assistance and funding to  States  to generate  the
data necessary  to make this assurance  (see  section  2.3.12 of this  Report).

     Finally,  the Agency  is  developing  guidance  for  entering  into  CAs with
federally recognized Indian Tribes  and working with the Bureau of Indian Affairs
and the Indian Health Service on how the operation  and maintenance assurance  can
be provided and how EPA will involve  Indians in the response process.  The  Agency
develop implementing guidance that will address Indian involvement  in hazardous
substances response, just  as  it  now does  for States.   In addition, the revised
NCP includes Indian participation provisions.
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4.0   PUBLIC INFORMATION AND COMMUNITY RELATIONS

     4.1  Public Information

     EPA has  developed  several resources that members of the public  can use to
obtain information about  the program  in general,  to get  an  answer to  a question
about a particular Superfund site, or to get an update on regulatory development
activities.  In addition, EPA has established an Ombudsman to resolve  complaints
about Superfund actions.

     4.1.1  Superfund Hotline

     The  Superfund  Hotline (1-800-424-9346;  382-3000 in D.C.)  is  EPA's public
information service for Superfund-related questions.  During calendar  year 1987,
the  Hotline  received  a  total  of   19,376   inquiries:    16,346  requests  for
information and 3,030 document requests.  The number of  inquiries has increased
steadily each year.

     The Hotline provides help with interpreting CERCLA,  as amended by SARA,  and
SARA provisions and  related regulations, and answers a wide range  of questions
on the Superfund program.   If  an inquiry cannot be  answered by  the Hotline,  the
information specialist  will refer  the  issue  to  the appropriate office (e.g.,
Office of  General Counsel)  and will report the information back  to the caller.
Document  requests  are   also   handled by  the  Hotline;  orders  are  taken  for
publications  or the caller  is  referred  to  the correct source.

     In  addition  to  responding  to questions  about  EPA activities, the Hotline
can refer callers to the correct State or Regional coordinator.   Questions about
Title III  (Emergency  Planning  and Community Right-to-Know) were  not  handled by
this service  during FY87.

     4.12  Superfund Docket and Information Center

     The Superfund Docket and  Information Center (SDIC) is the public  document
records center for rulemaking  actions and regulatory decisions under CERCLA as
amended by SARA,  and was established shortly  after enactment  of  Superfund in
1980.  Rulemakings and  records of proceedings under  the Emergency  Planning  and
Community  Right-to-Know  Act of 1986  (SARA Title  III) are also included.  Also
included are  CERCLA guidance documents  and directives, Records  of Decision,  and
information supporting rulemaking under  section 3012 of the Resource Conservation
and Recovery  Act  (RCRA).   The  docket supports EPA staff and management,  while
also serving  the public right  of access.

     The   rulemaking  dockets   contain   background   data,   public  comments   on
regulatory actions,  Federal Register notices, transcripts of public hearings, support
documents for regulatory decisions,  correspondence/memoranda,  and Administrative
Records.   The docket also prepares responses to requests under the  Freedom of
Information Act  (FOIA).   Rulemaking records which  have  had  prior  Office  of
General Counsel (OGC) approval  are available  to  the public  for viewing.   Copies
of  operating  directives  and   RODs   and signed  decision  documents   are also
available.
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     The public  is allowed  access  to docket materials upon announcement of the
rulemaking in the Federal Register.   No access is granted prior to  the  announcement
because (1) the Federal Register notice needs to be included in the  docket index as
part of  the  Agency's rulemaking rationale,  and without  it  the index  would be
incomplete, and  (2)  visitors would  have an unfair  advantage over  the general
public who rely on the Federal Register for notice of rulemaking.  The  SD1C responds
to all manner  of inquiries; specific requests  by  the public to view  files are
by appointment.

     The SDIC  is  located in Room M-2427  in  EPA Headquarters, at 401  M Street,
S.W., Washington, B.C.  20460.   The main telephone number for the  SDIC is (202)
382-3046  (docket appointments) and (202)  382-6940  (Superfund  documents/ROD
information).  SDIC hours of operation are Monday  through Friday from 9:00 a.m.
to 4:00 p.m.  The SDIC  is closed on  Federal  holidays.

     4.13  Public Information Center

     The EPA's  Public   Information Center (PIC) distributes  a  wide variety of
general,   non-technical  information  to  the   public  (202/382-2080).     EPA
publications  on  all  major  environmental  topics,   including   Superfund,  are
available through the PIC.

     When  the  public expresses  an interest in a  topic on which  there  are no
publications,  the center informs the appropriate  EPA Program Office  about the
public  interest  in  the  topic, so  that  the  office can  develop  appropriate
publications  or  fact  sheets.     In  addition  to  distributing  informational
materials,  the center  refers  requests  to  the appropriate  source.   The  PIC
maintains  a  limited on-site  inventory  of  publications,  and will  order other
publications from its Cincinnati warehouse.

     4.1.4  Hazardous Waste Ombudsman

     EPA has established an Office of Ombudsman at  Headquarters (202/475-9361)
and in each Regional office.  In FY87, the Ombudsman program  handled over 2,000
questions  and  complaints.   An  ombudsman  is an impartial  public  official who
investigates   questions   and   complaints   about  government   officials   or
administrative actions  and  seeks to  correct  problems where warranted.   The term
ombudsman originated in Sweden, where an ombudsman was  first  appointed in 1809.

     EPA's Ombudsman program is intended to assist  citizens and members of the
regulated  community  who  have  been  unable  to  voice a complaint  or  get their
problems  solved  through normal  channels.    The  program  is not   intended to
circumvent   existing   channels   of  management    authority   or   established
administrative and formal avenues  of appeal.

     42  Community Relations

     In  addition to the general  information  activities  described above,  EPA
promotes  two-way communication between  the communities  affected  by  specific
releases of hazardous substances and the lead government  agencies  responding to
those releases  through  its  Superfund community relations program.   The program
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ensures that the  local  public  is  provided with accurate and timely information
about the progress of response plans.   This information enables  the local public
to  comment  on and  help make  decisions about  response actions.   A  thorough,
well-planned community  relations  effort is an integral part of every  Superfund
response.

     Even before  the CERCLA was  enacted  in  1980,  EPA began  development  of  a
community relations  program that  would be able  to  respond to  the  variety of
interests and information needs of diverse site communities across the country.

     42.1  Public Participation Under CERCLA Section 117

     Beginning with  enactment  of SARA, EPA  implemented requirements  necessary
to  comply with  CERCLA section 117 public  participation provisions and expects
to  complete  implementation in FY88.   The revised NCP will include additional
regulations  on  community  relations  that  reflect  CERCLA  requirements and the
experience  EPA has  gained  over  the past  seven years.    Currently,  EPA is
developing  guidance on  community relations  for  the   settlement  process,  the
litigation process,  and for Federal  facility sites subject  to CERCLA section
120.  All guidance and training programs,  including the handbook Community Relations
in Superfund,  will be  updated to comply with the  new  CERCLA requirements.   An
interim version  of this manual was  completed in October  1987.   New  community
relations fact sheets are also being  developed.

     Section  117 of CERCLA,  which  was  added by  SARA,  provides  for  public
involvement in the decisions made concerning cleanup  actions at  Superfund sites.
Section 117  requires that the public be informed of  proposed remedial action
plans; be given an  opportunity to  comment on these proposals;  be informed of
final plans, including  EPA responses  to public comments  on the proposals; and
be  informed  of  any actions taken that differ from the final  plans,  as well as
the reasons for the  changes.

     Naturally,  the efforts  made  by  EPA's  community relations program are
assisting in the implementation of the section 117 requirements.  Of particular
importance  is   EPA's long-standing  effort  to  incorporate  components  of the
Superfund community relations program into Superfund  technical activities.  This
past year, community relations skills training  was completed for more than 500
hazardous waste  officials in  14  States  as  well  as technical  enforcement and
community  relations personnel in  the  10 EPA  Regional  offices.     Community
relations training  has  been  incorporated as  a  module  in all  of  the  major
technical training programs, from the  CERCLA orientation training to the Record
of Decision Workshops for EPA staff.

     As EPA Superfund policy and  guidance documents  are developed and updated,
discussions  of  community relations  issues and activities  are  incorporated so
that EPA  and State  technical, enforcement,  and community  relations  staff are
equally knowledgeable and  encouraged to work as a team.   The Agency  continues
to provide support as well as initiate innovative community  relations activities.
This year, EPA produced fact sheets for public distribution and completed a pilot
project on dispute resolution for three EPA Regions.
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     422  Technical Assistance Grants Under CERCLA Section 117(e)

     In 1987, EPA requested comments from the public on its proposed regulations
implementing the technical assistance  grants  (TAG)  program.   The TAG program is
designed to provide funds to  communities for the  purpose of their hiring advisors
to interpret technical  information related to cleanup of Superfund sites listed
on the  NPL.   This  assistance  will provide affected communities with  a better
understanding of the nature of the site problems and alternative solutions, thus
allowing them to participate more effectively in the decisions made concerning
Superfund sites.  The TAG program can  provide grants of up to $50,000 per site.
Only one  grant  may be  issued  for each  site,  and  the community  is  required to
contribute 35 percent  of the amount required  to obtain  the  necessary technical
assistance.

     The comments  received on  the  proposed TAG regulations  were  considered in
formulating interim TAG regulations, which were  published on March 24,  1988 (53
FR  9736).    The  interim  regulations   enabled  the  Agency  to  begin  accepting
applications  and awarding  grants,  while it  continues  to   receive  additional
comments that will  be considered in developing the  final TAG regulations.

     423  Public Participation in Development of Administrative Records Under CERCLA Section 113(k)

     On May 29,  1987,  EPA issued a directive to its Regional offices that details
initial  implementation steps   to  meet  the  section  113(k)  requirement  for
administrative records  for the selection of response actions at Superfund sites.
Under  section 113(k),  EPA must provide  for the  participation of  interested
persons in  the  development  of the administrative  record for both  removal  and
remedial actions.   The  directive instructs  the Regional offices  to establish
administrative records  (if not already established)  at  each  Superfund site.   In
addition, the directive details contractor support  and  assistance  available to
the  Regional  offices   and   outlines   documents  that   must  be  included  in
administrative records.  The  directive  was  designed to assure that administrative
records would be established and in place in  time  for  FY87  ROD signatures,  and
to ensure consistency in the administrative records for different sites.
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5.0   PROGRAM AND IMPLEMENTATION SUPPORT

     EPA undertook a  number of program and implementation  support  initiatives
to facilitate the implementation of .CERCLA, train workers in health  and safety,
and expedite Superfund program progress.  A major  accomplishment was the creation
of  a  sophisticated  management  information  system,  which  was achieved by
consolidating and  improving previous administrative  support systems.   EPA also
assessed its training, technology transfer, and information dissemination needs
and began implementing  a  program-wide  strategy that resulted in more  than 200
presentations of 50 different courses to more than 11,000 attendees,  as well as
the publication  of a  number of  training documents.   Finally, EPA  diversified
its   contracting   program   and   delegated  increased   contract   management
responsibility to  the Regions in order  to  better meet  the needs  of  the removal
and remedial programs and to expedite completion of  response actions.

     5.1 Administrative System Support

     Access to the  information  contained in the following  seven data  bases is
essential  for  maintaining  EPA's  ongoing  capacity  to  implement  Superfund
activities.

     5.1.1  Modification of CERCLIS

     The first generation CERCLIS contained pre-remedial data on approximately
27,000 sites,  including  their identity and location, cost of cleanup,  descriptive
data,  and  Region-specific  data.   During  the  year,  EPA  implemented a  second
generation  CERCLIS by  incorporating  into the  existing  system part  of  the
information and data contained  in the following  four systems:

     •    The Superfund Comprehensive  Accomplishments Plan  provides
          data on all response  activities.

     •    The Removal  Tracking System provides a comprehensive removal
          data base that includes start  date, location,  lead agency,
          and NPL status.

     •    The Case Management System contains general  information on
          all  enforcement  activities,  with  information   on   cost
          recovery and  settlements.

     •    The Remedial/Removal Financial System  Site File tracks the
          actual obligations for operable units  for each  facility (or
          site) and event  (e.g.,  a RI/FS start) for site activities
          conducted under lAGs,  CAs,  or  contracts with  States, Indian
          Tribes, political subdivisions,  or other Federal  agencies.

     This expanded CERCLIS is the national reporting,  tracking,  and management
tool of Superfund.  The pilot  test of  the national data base was completed by
Region 9 in August 1987.  CERCLIS,  second generation, became operational at the
end of October 1987.
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     5.1.2  Superfund Comprehensive Accomplishments Plan

     The  Superfund  Comprehensive  Accomplishments   Plan  establishes  annual
activity and financial targets for the accomplishment  of response actions.  Each
year, EPA  Headquarters works  closely  with the Regional  offices  to  determine
program targets.   These  targets  are tracked  against program  accomplishments
throughout the year.

     In FY87, EPA improved SCAP's usefulness as a  planning and management tool.
First, EPA incorporated SCAP  into second generation CERCLIS and,  consequently,
the Regions became responsible for the planning and reporting that determine the
adequacy of budgetary allotments and how Regional  accomplishments are reported.
Second,  EPA began using SCAP  to track enforcement activities as well as remedial
and  removal  activities.   This  integrated approach  to  SCAP development  was
implemented in the following ways:

     •    Target  setting  and reporting for Fund-financed activities
          and enforcement/PR?  activities were  combined;

     •    Uniform reporting formats combining  removal,  remedial,  aind
          enforcement  information were  developed;

     •    The enforcement  case budget  was  integrated with  the  SCAP;
          and

     •    Regions  began planning the  use  of  Technical  Enforcement
          Support contract and interagency agreement resources  on a
          site-specific basis, the basis on which  remedial activities
          are planned.

     5.13  Strategic Planning and Management System/Action Tracking System

     The objective of the Strategic Planning and Management System (SPMS) is to
develop a  strong system of  integrated  planning,  guidance, and  oversight that
includes  the  States   in  EPA's planning and program  implementation.   The  EPA
Administrator  establishes long-term  strategies  and  a  priority  list.    SPMS
provides a framework  and system for accomplishing the  objectives laid out by the
Administrator.

     The Action Tracking System (ATS) is one component of SPMS.  It follows the
regulatory development of  major regulations, guidance,  and policies across the
Agency for all programs.   The  ATS provides the Deputy Administrator with reports
pinpointing potential  problems as regulations  and  guidance are developed.

     In September 1987, CERCLA and SARA were incorporated into ATS.  OSWER will
be required to track  supplemental  guidance and regulations listed in the "Agency
Operating  Guidance."  OSWER must also  track  any CERCLA or  SARA regulations
published bi-annually  in  the  Federal Register' s  "Unified Agenda."
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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     5.1.4  Superfund Enforcement Tracking System

     This data  base,  operated and maintained by the Office  of  Waste Programs
Enforcement (OWPE),  contains the names and addresses of  PRPs.  In FY87, the data
base was  expanded to include  the  NPL status  of  each site,   the date a notice
letter was sent to all PRPs, and the  contact person for each site.

     5.1.5  Case Budget System

     The Case Budget System tracks enforcement program work assignment activity
and funds  for the Technical  Enforcement Support  contracts.   This  system was
expanded to include fund requests,  actual fund allocations,  and work assignment
numbers.  As a result, contracts are  now more easily and accurately tracked.

     5.1.6  Cost Documentation Monitoring System

     This data base contains the requirements to support cost documentation for
section  107  case  referrals,  and  the  data  on documented  costs.     In  FY87,
information  on statutes  of  limitations for  section  107  cases began to  be
tracked.

     5.1.7  OSWER Directives System

     The OSWER Directives System provides a systematic  process  for  identifying
and communicating policy  and procedures  to  the Regions.   This Directive System
establishes a document numbering system designed to track and manage all current
program policy and guidance  related to implementation in  the Regions and States.
Additionally,  the System permits ease  in identification of  approval level  of
directive documents,  provides  a central Regional  location for  all  directives,
and maintains a comprehensive  index of valid directives.

     EPA considers only directives  that originate in or  are issued by  one of the
OSWER offices, Regional offices, or other EPA offices, and that affect at least
one  of  the  Regional Waste   Divisions   or  Environmental  Services  Divisions
appropriate  for  inclusion  in the system.    Also,  documents   issued by  the
Administrator  or  Deputy  Administrator  that are  not included  in  the  Agency
Directives  System will  be  included  in  the  OSWER Directives  System.    Each
directive is numbered to identify the originating office.  Superfund Directives
are numbered from 9200 through 9399 and  9800 through 9899.

     In FY87, EPA offices issued approximately 40  Superfund-related directives
and policies.  The following major directives were issued:

     •    CERCLA  Compliance  with   Applicable   or  Relevant   and
          Appropriate Requirements Guidance;

     •    Selection of Remedy  Guidance;

     •    Hazard Ranking  System  Revisions;

     •    Technical Assistance Grants;

     •    Nonbinding Allocation  of Responsibility  Guidance;  and

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


     •    De Minimis Settlement Guidance.

     52 Training Programs

     OSWER is responsible, under CERCLA section 311(b), for  the  coordination of
training  in  the  areas  of solid  and hazardous  waste and emergency  response.
Activities  related  to  these  responsibilities   include   long-range  planning,
analysis,  and evaluation; the identification of training requirements;  training
development,  delivery,  and  coordination within and  among  program offices;  and
management and training  support  to EPA  Headquarters, Regions,  arid States  as
requested.  The  overall  approach  to training being implemented by OSWER  is  one
that will  focus  training on improving  job  performance,  providing a consistent
format for training  development and delivery,  and maximizing the  effectiveness
of training resources through the use of  innovative  training methods.

     The recently established Office of Program Management  and Technology  (OPMT)
within the Office of Solid Waste and Emergency Response serves as  a  focal point
for coordinating research and  development,  technology transfer, and  training.
In conjunction with  the Office  of  Research  and  Development (ORD),  this  office
has specific responsibility for the development and  implementation of long-term
training and technology transfer strategies for OSWER.  Technological  innovations
developed through research and  demonstration programs  (such  as the SITE program
described  in  section  7.2 of  this  Report) are  incorporated  into  technology
transfer activities and training to ensure that advances  in knowledge and  skills
are made available to Superfund staff.

     52.1  Training Programs in Fiscal  Year 1987

     OSWER provided a large number  of training courses, seminars,  and workshops
related to critical training needs  as well as  in other areas such  as health  and
safety.  Approximately 50 different courses were  offered  during  the fiscal year.
In all, more  than 200 sessions were attended by approximately 11,000 individuals.
This represents  a substantial increase  over the  6,000 to  8,000  persons trained
in  FY86.    EPA  and  State  and  local  agency  staff  were  equally represented,
accounting  for  approximately 80  percent  of  trainees,  with the  remaining  20
percent distributed  among other  Federal  agencies,  contractors, and  industry.
Training  courses  were  offered  in  EPA   Headquarters,  EPA Regions,  and   at
Environmental Response Branch Training  Centers in Cincinnati, Ohio,  and Edison,
New Jersey.

     OSWER's FY87 extramural  budget for Superfund training  activities  included
training funded by EPA Headquarters, continuing training  in safety and Superfund
operations operated by OERR's Emergency Response Division,  and additional funds
expended  by  the Regional offices.   OSWER awarded  more   than  $43,000,000  in
training contracts.

     522  Meeting  Critical OSWER Training Needs

     OSWER completed a  training needs  assessment in March 1986  that identified
several areas in which it considers training a high-priority need:   ground-water
monitoring, CERCLA regulations,  risk, remedial engineering,  cleanup technologies,
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


community relations, compliance monitoring, contingency planning, and on-scene
coordination.  To meet these training needs,  EPA developed the  following  tools:

     •    A draft Ground Water Curriculum and Implementation Plan that
          identified  ten  critical  training  needs   in   this  area.
          Efforts are underway to develop the required training.

     •    A  National  SARA Videoconference  that was  viewed by over
          5,000 persons in March 1987 and was followed by  a series of
          regional SARA Implementation Meetings in six major cities.
          In addition,  the  CERCLA  orientation course was revised to
          reflect the new CERCLA provisions.

     •    A Risk  Assessment  course  focusing on the Superfund  Public
          Health Evaluation Process that was delivered in  all ten EPA
          Regional offices during FY87.

     •    A  training  module entitled Hazardous Waste Cleanup Tech-
          nologies and Their Application at Superfund Sites that was
          piloted in early FY87 and covered the existing state-of-the-
          art in  hazardous  waste engineering methods.  A seminar on
          innovative and emerging cleanup and engineering technologies
          was also  presented in concert with ORD's  Hazardous Waste
          Engineering  Research  Laboratory  as a part   of OSWER's
          technology transfer series.

     •    A  Superfund  Community  Relations  Training  Strategy that
          included proposed courses for implementation in FY88.

     •    A focused task analysis for Superfund Enforcement Compliance
          Monitoring  that concentrated on  the functional  areas  of
          ground water and incineration.

     •    The National Response  Team  (NRT)  Training Strategy,  in
          coordination with  other  NRT agencies,  to address training
          in the areas  of contingency planning and  hazardous  materials
          response.  The strategy addresses  several issues  related to
          interagency  coordination,  needs  assessment, task analysis
          and identification of training  target  audiences,  and  it
          suggests implementation activities  in each area.

     •    A  draft  On-Scene  Coordinator/Remedial  Program  Manager
          Training   Curriculum   to  provide  Superfund  on-scene
          coordinators  (OSCs)  and  remedial  program  managers   (RPMs)
          with  task-related  training critical  to fulfilling Agency
          objectives.   The curriculum delineates required,  optional,
          and specialized courses for Superfund employees.

     523  OSWER Training Documents

     In an effort to  implement a comprehensive OSWER training and technology
transfer program and execute the responsibilities of the new Office of Program


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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


Management  and Technology,  OSWER  has  developed  several training  documents.
Among the most  significant of these are the following:

     •    The  Technology Transfer Strategy was  developed  in April  1987  to
          assist  OSWER   in  disseminating  innovative  and  emerging
          environmental  research activities at  the leading  edge  of
          technology.

     •    The OSWER Training Implementation Plan presents a management plan
          to address the  major recommendations  contained in the OSWER
          Training  Strategy.

     •    The OSWER Training Policies and Procedures document is  intended to
          be used by  Headquarters and the Regions as a guide to the
          conduct of training activities.  The  document addresses the
          areas of curriculum planning and revision, needs  definition,
          training  priorities,   course   development  and   deliv€;ry
          activities,  and training evaluation and program  management.
          Volumes I and II of the policy document were issued as OSWER
          Directive No.  9018.00-2,  September 30,  1987.

     5.2.4  Organizational Improvements

     OSWER  has   made   significant  progress   in   implementing  organizational
improvements related to greater coordination and increased management commitment
to  training and  technology.   A brief description  of several major  program
accomplishments follows.

     Superfund Work  Force Planning Project

     Early  in  the  fiscal  year,  OSWER  created  a  task  force  made  up  of
representatives of  the Office of Human Resource Management  (OHRM),  OSWER, and
several of  the  Regional offices  to  implement the  recommendations  contained in
the  Superfund  Work  Force  Planning  Study.     Efforts  to   implement  the
recommendations of  the study and the  subsequent GAO Report to Congress on Superfund
Improvements Needed in Work Force Management,  dated October 1987,  are underway.  A plan
is currently being  developed and is scheduled  for implementation in FY89.

     Technology Transfer

     The Technology Transfer Strategy,  issued jointly  by OSWER and ORD in April 1987,
outlines  a  systematic  approach for  disseminating  information.   The  strategy
focuses on  creating an  organizational  framework  within  which  the  Agency can
better define problems in the field,  develop and disseminate technical products,
and  evaluate  the  effects of  those  products.    Proven  techniques are  then
transferred to Regional,  State,  local  and private sector users through training
and other methods.
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


     National Response Team Training Committee

     The NRT  Training Committee  is  responsible  for  coordinating training  in
contingency planning and hazardous materials response among the member agencies
of the NRT.  In FY87, the NRT Training Committee:

     •    Supported a Hazardous  Materials training conference  in  an
          effort to establish Federal, State, and local relationships;

     •    Developed a  concept paper on how best  to establish  focal
          points for coordinating State and local  hazardous  materials
          training;

     •    Coordinated meetings and conducted briefings for national
          trade   organizations    to   increase   private   industry
          participation in a coordinated hazardous materials training
          system;

     •    Provided  support  for the development of a videoconference
          on public health  impacts of hazardous materials  incidents;
          and

     •    Conducted a focused task analysis for local  response  teams,
          hazardous materials teams,  and medical teams to ensure that
          training  is related to job requirements in  this area.

     Training for Other Federal Agencies

     As  part  of  its  coordination with  other  Federal agencies  in  hazardous
substance response, OSWER provided specialized training in EPA's hazardous waste
programs and  policy to both  the  National Park Service  and the Indian  Health
Service.  As a part of the  Department of the Interior  training  program for Park
Service Safety Officers, the  Technology Staff of OPMT developed and delivered
specialized training that emphasized  the handling of hazardous materials and the
responsibilities of Federal facilities under Superfund.  For the Indian  Health
Service of the Department  of Health  and Human Services, a  course  providing  an
overview of the  Superfund  program and EPA's Indian Policy was  developed.  The
training  also  reviewed  the  legislative  background of  jurisdictional  issues
involving hazardous waste releases on Indian land.

     5.2.5  Future of Training Programs

     OSWER has developed a structured and  organized  training program to  meet
Superfund program needs, and has developed plans and policies to provide focused
and coordinated training, improved training capacity,  and a  stronger  commitment
to training.   Future  training  funds budgeted  for  Superfund will be used  to
implement innovative training methods to increase  the  effective use of training
resources.   OSWER will  build  upon  the accomplishments  outlined  above  to
implement the ideas that have  been developed in both the training and technology
transfer areas.  The  Superfund program will develop the technology  assistance
concept, and OSWER will  work toward developing the means to  expand opportunities
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


for the participation of small and minority business enterprises in training and
technology transfer.

     53 Contracting Support and Programs

     53.1  Overview

     EPA used contracts  in five categories to implement the Superfund program:
(1) Headquarters/Regional policy and program implementation; (2) removal action;
(3)  remedial action;  (4) enforcement  support;  and  (5)  contract  laboratory
services.    In  FY87,  the  Superfund program  administered 153 active  contracts,
with a potential value of $2,363,355,000:

     •    Six  contracts, with  a  potential  value  of $63,000,000,
          support  Headquarters  and  Regional  programs  for   policy
          development  and implementation.   Under  these   contracts,
          contractors   provide  both   technical  and  non-technical
          assistance.

     •    One hundred thirteen contract laboratory contracts,  with a
          potential  value of  $288,000,000,  supported the Contract
          Laboratory Program (CLP)  to  provide  laboratory services  for
          both removal and remedial actions.  The greatest number of
          Superfund contracts fall into this category.

     •    Seventeen contracts, with a potential value of $946,255,000,
          supported  the  removal program.   Removal program contracts
          provide  EPA  with support  in  emergency  response,   other
          removal actions, spill prevention, and analytical services.

     •    Nine remedial  action  contracts  provide  EPA with technical
          assistance during RI/FS, remedial design,  and construction
          stages.    These  contracts  have  a  potential  value  of
          $925,600,000.

     •    Eight enforcement contracts  assist EPA in cost recovery  and
          litigation  support  operations.    Combined  they  have a
          potential  value of $140,500,000;  seven  of the  eight were
          awarded in FY87.

     Of these 153 active contracts, a  total of 136 were awarded during the year,
with a  potential value of $1,503,855,000.  Exhibit  5.3-1 lists  FY87 contract
awards and their potential value.

     Two  significant  contract  initiatives are represented among  the contracts
awarded in  FY87:  the  Alternative  Remedial Contract  Strategy (ARCS)  and  the
Environmental  Services  Assistance  Teams  (ESAT)   contracts.    ARCS  contracts
perform  the same  functions  as,  and  will  replace,   remedial  planning  (REM)
contracts.   They are,  however,  awarded on a  Regional  basis  rather  than on  an
east-west zone basis.  The ESAT contracts will  provide laboratory services,  as
requested, to all areas  of the Superfund program.
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                 Progress Toward Implementing Superfund: Fiscal Year 1987
                                    Exhibit 5.3-1
                          Fiscal 1987 Contract Awards
            Contract
Number of
Contracts
Length of
Contracts
            General Policy and         4     Up to 5 years
             Technical Support

            Response  Support:

                  Laboratory        110     Up to 4 years
                  Removal          16     Up to 5 years
                  Remedial           5     Up to 5 years

            Enforcement Support      	1     Up to 4 years
            Total                  136
 Total
Potential
 Value
                            $43,000,000
                           $221,000,000
                           $903,755,000
                           $325,600,000

                            $10.500.000
                         $1,503,855,000
     53.2  Response Support Contracts

     Laboratory Support Contracts

     During  the fiscal year,  EPA awarded  110 new contracts  to provide  sample
analysis services under the Contract Laboratory Program.  These contracts  have
a potential value of  $221,000,000.   The CLP provides laboratory service for all
removal, pre-remedial,  and remedial actions, and  is  responsible for  analyzing
samples taken at various  stages  of the cleanup process.   EPA  awards  contracts
for organic,  inorganic,  and  dioxin analytical  services.   These  contracts  are
awarded continually,  depending on capacity needs.

     In FY87,  the CLP ran a  total  of 91,524 Superfund  site samples.   Most  CLP
analysis is done  for  site samples taken during RI/FSs.  Exhibit 5.3-2  shows the
annual number  of RI/FS  site samples analyzed by the  CLP since  the inception of
the Superfund  program.

     Organic   and  inorganic  samples,   because   of   different    contractual
requirements,  have different  result turnaround times.    The  median processing
time for an organic sample is 32 days and for an inorganic sample it  is 31 days.
Sample results are returned to  the Region for review,  the  length of which varies
from several days to  several months.  With few  exceptions, turnaround times on
average have been maintained below the contract-allowed 40 days.   Data
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                Progress Toward Implementing Superfund: Fiscal Year 1987

                                  Exhibit 5.3-2
                     Site Samples Analyzed For Remedial
                       Investigations/Feasibility Studies
                                by Fiscal Year
Fiscal Year
1980
1981
1982
1983
1984
1985
1986
1987
Samples Analyzed
1,500
5,000
16,000
43,000
52,000
71,000
71,000
80,000
compliance with the quality assurance/quality control requirements is above  the
90 percent level for the first time.

     EPA's  latest  awards  in  support of  the  laboratory program  are two ESAT
contracts worth $35,000,000 each.  These two contracts,  both awarded at  the  end
of FY87,  provide assistance to EPA's Regional offices in laboratory,  analytical,
and review  services.   The contracts cover different  geographical  zones  (the
eastern zone includes Regions 1,  2,  3,  4,  and the western zone  includes  Regions
5, 6,  7,  8,  9,  10,  and HQ).  Their periods of performance can extend to  4 years
depending on the number of options exercised.

     Removal Support Contracts

     The removal program traditionally has been supported by Emergency Response
Cleanup Services (ERGS) contracts.  The ERCS contracts were  recompeted this year
and awards range in potential value  from  $60,000,000 to  $165,000,000 over a 4-
year period  of performance.   ERCS  contractors operate  on  a zone basis, with
several EPA Regions included within  each  of four zones:

          Zone  I:   Regions 1, 2, and 3;
          Zone  II:  Region 4;
          Zone  III: Region 5; and
          Zone  IV:  Regions 6, 7, 8, 9, and 10.
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


Also, EPA developed and began implementation of a  strategy for  awarding smaller
removal contracts, "mini-ERCS, " on a Regional basis.   EPA also  plans  to provide
additional support to the Regions  in FY88 by dividing one of the ERGS  zones into
two smaller zones and awarding a contract for  each of  them.

     Four contracts were awarded to support  the dioxin removals being conducted
at Castlewood and other  related  sites in the St.  Louis, Missouri area.  These
contracts have a total potential value of approximately  $75,452,000, over a 4-
year period.  EPA also awarded a contract with a potential value of $703,000 to
conduct a site-specific removal at  the American Steel Drum site in Bedford, Ohio
in EPA Region 5.

     EPA awarded two Technical Assistance Team (TAT)  contracts  in December 1986
to replace the previous sole  TAT contract.  The combined potential value of both
contracts over a 5-year period of performance  is  $219,0000,000.   Each contract
covers a different portion of the country.  The eastern  zone contract supports
Regions 1-5,  the  Emergency Response  Team, and EPA  Headquarters.  The western
zone contract supports Regions 6-10.   The TAT contracts serve as adjuncts  to the
ERGS contracts and provide for initial site  response  support, determinations of
the size and nature  of the site,  and support  for On-Scene Coordinators  during
actual cleanup.

     This year, the  Environmental  Emergency Response Unit (EERU) contract was
divided  into  three  separate contracts,  a  Response  Engineers and  Analytical
contract, an  Environmental Response  Training  contract,  and an EERU contract.
These contracts provide emergency response support to  hazardous waste sites or
spills posing an  immediate  threat.   These first two contracts were  awarded in
FY87.  The  Training  and Response  Engineers  contracts will run for 5 years and
provide up to  $138,000,000 in support, primarily to provide engineering response
for the Environmental Response Team's field activities.

     One ERGS contract was awarded to an 8(a)  (minority)  firm.   This  contractor
will also be allowed to perform small remedial operations.  The  contract has a
potential value of $12,253,000 and extends from October  1987 through September
1988.  Two Regional ERGS were awarded, both of which are  also  8(a) contracts.

     Remedial Support Contracts

     EPA  developed  and  commenced  implementation of the  ARCS,  a substantial
change  in  its remedial  contracting  program.   The  ARCS concept is aimed at
maximizing competition in the remedial program, providing  additional incentive
for  improved  performance, and  promoting project continuity.    There  will be
numerous smaller  remedial response contracts awarded continuously in each Region
or, in some cases, in several Regions combined.   Each  Region will award  six to
ten contracts.

     Work will be assigned to  these contracts based on quality of performance
and the  program  will  emphasize  keeping  the  same contractor  involved  in all
phases of the cleanup process.   The first awards were made in EPA Regions 3 and
5  in  January 1988;  coverage in all  Regions  is  planned by the  end of  FY89.
Contracts will range from $60,000,000 to $250,000,000 in potential value over
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


10-year periods.  As  in the  current  remedial contracts, the ARCS will  contain
large subcontracting pools to maximize the number  of contractors participating.

     Two  Field Investigation  Team (FIT) contracts  were  awarded  in  FY87  to
provide  support for  pre-remedial activities;  each  has  a  5-year  period  of
performance and  will  expire  in November 1991.   One of  these  contracts has  a
potential value  of  $130,000,000 and  provides  support for Regions  1-4 in  the
eastern half  of the  country.   The  other  contract has a potential value  of
$150,000,000 and supports Regions 5-10 in the western half of the country.

     Minority  business  firms  were  awarded  two  smaller contracts  to  perform
remedial response activities.  They have a potential value  of $21,500,000 each,
and have 4-year periods  of performance.  EPA also awarded a  single  contract with
a potential value of  $2,600,000 designed specifically to  procure support  for
remedial response activities at the Wausau,  Wisconsin  site through  1991.

     Enforcement Support Contracts

     EPA awarded one contract,  with a potential value of $10,500,000,  to  provide
litigation services  for cost  recovery, support  PRP searches, and fund oversight
for PRP and Federal  facility cleanups under both CERCLA and RCRA.

     5.4 Superfund Resource Utilization

     This section presents data and information on the  utilization of resources
from  the  Hazardous  Substance  Trust  Fund  (Superfund)  for  implementation
activities by  EPA and other  Executive  branch  departments and  agencies in  FY
1987.  The data and  information included in this section were obtained primarily
from EPA Superfund budget documents.  Superfund resource requirements of EPA and
other Executive branch departments and agencies for FY  1988-1991  and beyond FY
1991 are discussed  in Chapter  13.

     EPA uses  Superfund resources in four major areas:

     •    Hazardous  Substance Response;
     •    Enforcement;
     •    Management and  Support; and
     •    Research  and Development.

Both  EPA  Headquarters  and  the   Regional   offices  perform  these  Superfund
activities.  Fiscal  year and  historical transfers  to Regional offices are shown
in  Exhibits  5.4-1  and 5.4-2.   In addition,  EPA  transfers resources to other
Federal   departments   and   agencies   to   assist  them  in   meeting  their
responsibilities under   CERCLA.    The Agency  also transfers  funds  from  the
Superfund  appropriation  to   State   governments   and  other  private  sector
organizations  (e.g., the  National Governors'  Association)  to assist  EPA in  the
implementation of CERCLA.

     In  FY 1987,   the  Agency utilized a total   of  $1,050,748,900  from  the
Hazardous Substance  Superfund appropriation for CERCLA  implementation, including
SARA  Title III  activities.     Superfund implementation  activities  that  EPA
conducted under the four  major program areas accounted for $984,600,900.   The


                                       82

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               Progress Toward Implementing Superfund: Fiscal Year 1987
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


Agency utilized a total  of $66,148,000 for Superfund general interagency support
to  other Federal  departments and  agencies,  including  Superfund  Interagency
Budget transfers and site-specific interagency agreements.

     5.4.1  EPA Superfund Program Activities

     EPA  utilized a  total  of $984,600,900  (94  percent  of  the  total  amount
obligated from  the Trust Fund)  to conduct Superfund implementation activities
under the Hazardous Substance Response, Enforcement, Management and Support,  and
Research and Development programs.  These activities were  supported by a total
of  2,174.3  workyears at  both EPA Headquarters  and in  the Regional  offices.
Exhibits  5.4-3,  5.4-4,  and  5.4-5 illustrate current  and historical  resource
utilization.

     Hazardous Substance Response

     The two Hazardous Substance Response programs, Spill and Site Response  and
Hazardous Substance Response Support,  are utilized to protect public health  and
the environment  from  dangers  associated with releases of hazardous substances
into the environment.  These programs  provide the  necessary funding and support
to  undertake  short-term emergency  responses  and  long-term  site  cleanups.
Activities  include  responding to  spills  and emergency  releases  of  hazardous
substances, conducting  remedial  work at abandoned hazardous waste  sites,  and
providing training and technical support to Agency, State,  and local government
personnel.

     The  majority of  the  work  performed  under  the Spill  and Site  Response
program  was geared  toward  implementing CERCLA  provisions  and regaining  the
momentum of the  Superfund program.   The regulatory and guidance  framework  for
the  removal  program was  completed,   including   the use  of  revised  removal
authorities and  the  promulgation of  final regulations on CERCLA  notification,
reportable  quantities,  and the designation of additional hazardous  substances.
The Agency  focused its  remedial  efforts on  initiating Rl/FSs at NPL sites  and
beginning design and implementation at sites where planning was completed.

     Enforcement

     The  primary goal of Superfund  enforcement  activities  is  to  achieve  the
maximum  possible response  from potentially  responsible parties.    Superfund
enforcement activities are conducted through four programs:  Technical Support -
Office of Enforcement and Compliance Monitoring (OECM); Technical  Enforcement;
Legal Enforcement; and  Criminal  Investigations.

     The  OECM  program  supports the  Superfund  activities  of  the  National
Enforcement  Investigations  Center  (NEIC),   including  special  environmental
monitoring  work,  evidence  audit control processes to  ensure proper  chain-of-
custody  procedures,  cleanup  of  Federal   facility  sites,   and   nonbinding
preliminary allocations  of  responsibility.   The  Technical  Enforcement  Program
develops  the  technical  documentation for Superfund enforcement and  initiates
enforcement actions.   The Legal Enforcement program provides the legal staff  for
CERCLA enforcement.   EPA Headquarters support for judicial enforcement  under
this program increased  in 1987 as EPA set precedents with new types of


                                      85

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                        Progress Toward Implementing Superfund:  Fiscal Year 1987
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      Progress Toward Implementing Superfund:  Fiscal Year 1987
                          Exhibit 5.4-4
           Fiscal 1987 Superfund Resources by
                 EPA Office and Function
EPA Office
Function
Hazardous Substance
Response Action
AA Air and Radiation
AA Water
AA Pesticides and Toxic
Substances
AA Solid Waste and Emergency
Response
Enforcement
AA Pesticides & Toxic
Substances
AA Solid Waste and Emergency
Response
AA Enforcement and Compliance
Monitoring
Management and Support
AA Research and Development
AA Administration and Resources
Management
AA External Affairs
Administrator/Staff
Inspector General
General Counsel
AA Enforcement and Compliance
Evaluation
Research and Development
AA Research and Development
Superfund Total*
Dollars
(in thousands)
$840,902.6

1,216.5
1,803.9
5,079. 1

832,803. 1

100,356.3
1.9

82,948.5

17,405.9

69,771.6
216.9
59,955.9

47.8
87.5
4,581.2
1,399.8
47.8

39,718.4
39,718.4
$1,050,748.9
Full-Time
Equivalent
963.4

7.5
9.5
2.7

943.7

764.5
.

529.7

234.8

353.0
-
269. 1

5.0
-
45.7
29.7
8.0

93.4
93.4
2,174.3
'Includes resources utilized for interagency support and SARA Tide III activities.
                              87

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Progress Toward Implementing Superfund:  Fiscal Year 1987
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                 Progress Toward Implementing Superfund: Fiscal Year 1987


enforcement  activities,  such  as de minimis  settlements,  consent decrees  with
responsible  parties to  undertake  response actions,  and  civil remedies  for
reportable quantity violations.   The basic purpose  of  Criminal  Investigation,
under the direction of NEIC, is to initiate and conduct criminal  investigations
under CERCLA.

     Management and Support

     Superfund  management  and   support activities  provide the   financial,
administrative,  and support  services necessary  to manage  and  implement  the
Superfund program.  These activities include:   financial management to track and
report  on  the  use  of  the   Hazardous  Substance  Superfund;   administrative
management of  contracts  personnel,  information systems,  office  and  laboratory
services, and  safety  training; services  for  space,  utilities,   and  other  non-
personnel support needs, including  computer services.

     Management  and support also includes  legal services;  auditing services;
policy  analysis  and  program  evaluation;  budget development  and  oversight;
effective  communication  with  interested  parties  outside  the Agency;   and
laboratory support  for  Superfund research.   The Agency performs its Superfund
management and support activities under  the following  nine  program areas:
(1) Financial Management; (2) Administrative Management;  (3) Support Services;
(4) Computer Services;  (5)  Legal Services;  (6)  Office of the Inspector General;
(7) Office of Policy, Planning, and Evaluation;  (8)  Office  of the Comptroller;
and (9) Office of Research  and Development.

     Research and Development

     Superfund research and development  activities  support  the Agency,  States,
and  industry  in resolving  technical   problems  that  inhibit  the   effective
implementation  of removal  and remedial actions.   Much  research   focuses  on
adapting existing technologies and  scientific information for   the  purpose  of
controlling hazardous waste.

     Superfund  research  and  development  (R&D)  activities provide  quality
assurance protocols and methods  for  sampling and  analyzing hazardous waste
materials.   Superfund R&D also develops techniques for field response personnel
to use  in  evaluating  potential  sites,   and  engineering  and other  technical
guidance for  Federal,  State,  and  local  officials  to  use  in conducting  site
cleanup operations.   Superfund research  also  includes evaluation of personal
protective devices and engineering  controls to protect  hazardous waste workers
and improve  their efficiency.  Superfund  research and development  activities are
conducted through the following seven programs:  (1)  Scientific Assessment;  (2)
Monitoring  and  Quality  Assurance;  (3)  Health  Effects;   (4)   Environmental
Engineering  and  Technology;   (5)   Environmental  Processes  and  Effects;   (6)
Exploratory Research; and (7) Technical  Information  and Liaison.

     5.42 Other Executive Branch Department and Agency  Superfund Activities

     Two sources of funding meet  the resource needs of other Executive branch
departments  and  agencies  for  CERCLA  implementation:   (1) monies obligated  to
these departments and  agencies by  EPA  from the Hazardous  Substance Superfund
                                       89

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


appropriation, and (2)  funds independently budgeted by other Federal departments
and agencies.

     In  FY87,  EPA transferred  a  total  of  $66,148,000  from  the  Hazardous
Substance Superfund  appropriation to other Federal  departments and agencies.
EPA  transfers Trust  Fund monies  to other  Federal  departments  and agencies
through an interagency budget process under  Executive Order 12580 that utilizes
general and site-specific interagency agreements  (lAGs).   General lAGs,  funded
through   either   transfer  allocation  or   reimbursable   accounts,   provided
$51,343,100 for  ongoing activities that generally are  not incident-specific,
such as developing program policies and guidance, training response personnel,
and conducting  health  research.   Site-specific  lAGs provided $14,804,900 for
those activities  that  are episodic  in  nature and taken  in direct support  of
specific site  or spill  response actions.   Site-specific activities are generally
paid for  on a  reimbursable  basis.    Exhibit  5.4-6  presents  data  on the FY87
Superfund interagency  agreements by department and agency.

     The  second  source of funding  used to  meet  other  Federal department and
agency Superfund  resource needs  is monies  that  are  independently budgeted  by
individual departments or agencies for Superfund activities and support  as part
of  the  President's  annual budget  submission.    This  source of  funding for
Superfund activities is discussed in Chapter  13.

     Department of the Interior

     The NCP  also designates  the Department  of  the  Interior  (DOI) as  Federal
Trustee for certain natural  resources either  lost or damaged due to hazardous
substance releases.  DOI provides scientific  and  technical  support in resource
damage  assessments through  its   participation  on the  National  and Regional
Response Teams.

     Department of Transportation

     The  United  States  Coast Guard  (USCG)  is  a part  of the  Department  of
Transportation (DOT), except when operating  under the Department of the  Navy  in
time of war.  The USCG is the  predesignated  On-Scene  Coordinator in the  Coastal
Zone and has the authority under  CERCLA  to respond to any  release or threatened
release of hazardous substances involving the shore,  Coastal  Zone, Great Lakes
waters, ports,  and harbors.   The USCG and EPA  share  responsibility  for the
emergency response activities under  the NCP.   The  USCG  provides  training  to
maintain this  response capability, conducts  enforcement  activities  as necessary
in  its areas  of responsibility,  maintains  the National Response Center  (NRG),
and supports the National Response Team and each of the Regional Response Teams.
In addition, the USCG  (under section 108(a)  of CERCLA) enforces the requirements
that commercial  vessels using U.S. waters  must  provide evidence of financial
responsibility to  pay  for cleanup in  the event of spills.

     The Coast Guard utilized 1987 transfer  funds to  purchase  safety equipment,
conduct response  training for USCG  personnel, upgrade the  capabilities  of the
NRC, and  provide  field data  systems to  support response programs and minimize
the possibility of harm  to personnel  from exposure to hazardous substances.
                                      90

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
                                   Exhibit 5.4-6
            Fiscal 1987 Superfund Interagency Support Resources
            Federal Department                     Dollars
               or Agency                      (In thousands)
            Department of the Interior                 $  687.0
            Department of Transportation                 4,023.3

            Department of Health and Human Services     32,439.3

            Department of Commerce                   1,819.9

            Department of Justice                     10,918.6

            Department of Labor                        281.3
            Federal Emergency Management Agency       1.173.7

                     Total                       $51,343.1
     Department of Health and Human Services

     Within  the Department of Health and  Human Services (HHS),  the Agency  for
Toxic  Substances and Disease  Registry  (ATSDR)  and  the National Institute  for
Environmental Health Sciences  (NIEHS)  have certain Superfund  responsibilities.
ATSDR  can  investigate  complaints of illness  or disease related to exposure  to
hazardous  substances,  conduct health studies and surveys,  develop testing  for
exposed individuals, and develop  and maintain information on the health effects
of toxic  substances.  Under CERCLA,  ATSDR must perform health assessments  by
December 10, 1988 at all sites  that were listed on  the NPL as  of October  17,
1986.   HHS develops policies  and  procedures to ensure a  coordinated  Federal
approach in conducting the above activities.  NIEHS  administers a training grant
program in worker protection and  a  program for basic  research, development,  and
training  to  promote  better understanding of  the  effect  on human  health  of
exposure to hazardous  substances.

     With  the  funds EPA transferred  to it,  HHS  collected  the information  and
developed the procedures necessary  to provide continuing health-related support
to the Superfund program.  Included in these efforts were development of health-
related field guidance in support of EPA emergency response actions; development
of standard  guidelines for  health and epidemiological studies at NPL  sites;
production of worker health and safety technical guidance and  field manuals  for
individuals involved in response actions;  and toxicological testing of chemicals
found at NPL sites.
                                       91

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
     Department of Commerce

     The National  Contingency Plan designates  the  National Oceanographic  and
Atmospheric Administration (NOAA) to act on behalf of the Secretary of Commerce
as Federal Trustee for natural  resources  in coastal and marine areas  that  are
lost  or damaged  due to  hazardous substance  releases.   NOAA  also  provides
scientific and technical support for responses to such  releases in coastal  and
marine  waters.    Transfer  funds received  by NOAA  provided  training for  the
scientific response team, the purchase and maintenance  of protective  equipment
for personnel,  the  development  and maintenance  of  field instrumentation,  and
the development of computerized contingency plans.

     Department of Justice

     The Department of Justice (DOJ) is responsible  for  the  conduct and control
of all litigation under CERCLA.   EPA is responsible  for preparing  the required
technical and legal documentation and cooperates with DOJ in  negotiating consent
decrees for  privately  financed  response actions.   With the transfer  funds  it
received  from EPA,  DOJ  provided  civil  and criminal  enforcement  litigation,
including counseling on  and  enforcement  of administrative orders  and warrants
for entry, and institution of suits to compel removal and remedial actions  and
to recover Superfund response costs.

     Department of Labor

     The Occupational Safety and Health Administration (OSHA)  of the Department
of Labor  is  responsible for  worker protection at  Superfund  sites.   The OSHA
Health  Response  Team assists EPA   and  other  on-site personnel  in protecting
workers at  Superfund sites  and in developing  guidelines  to improve current
methods of worker protection.  OSHA utilized transfer funds to  provide  technical
assistance to  EPA,  initiate  a special program  for  worker safety  at  Superfund
sites,  support  National  and  Regional  Response  Teams,  and  develop a  required
worker protection standard.

     Federal Emergency Management Agency

     The  Federal  Emergency   Management  Agency's  (FEMA) hazardous  materials
(HAZMAT) program involves working with Federal, State, and local governments  and
the private sector to provide guidance, deliver technical assistance, facilitate
information  sharing, and promote interagency/intergovernmental coordination in
the areas of emergency preparedness, response, and mitigation.   The overall goal
of FEMA's HAZMAT  program is  to  reduce the frequency and severity  of  hazardous
material emergencies by  enhancing  the prevention and response capabilities  of
Federal, State, and local agencies, and of the private  sector.  Much  of  FEMA's
HAZMAT  program is  accomplished through  the  National  Response  Team and  the
Regional Response Teams.   In the  event of an emergency, FEMA assists  in  the
temporary or permanent relocation of individuals whose  health is threatened by
the release  of hazardous materials.
                                       92

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


6.0   EPA RULEMAKING ACTIONS TO IMPLEMENT CERCLA

     SARA created many new regulatory authorities under CERCLA.  In response to
these new  authorities,  and as  part  of ongoing rulemaking activities,  EPA and
other Federal agencies involved in the  Superfund program initiated a significant
number of rulemakings during FY87.

     Rulemaking  activities  that address  specific  Report  chapter  topics  are
discussed  in the appropriate chapter  sections:   reportable  quantities (2.1);
the remedial program (2.3); and State involvement (3.2).   Additional rulemaking
activities were undertaken for  the following  other  regulatory authorities.

     6.1 Designation of Hazardous  Substances Under CERCLA Section 102 (a)

     In the  preambles  to  rulemakings published on March 16,  1987  (52 PR 8140,
8142) and  April  22,  1987  (52 FR 13378,  13392),  the  Agency  indicated  that it
intends  to  designate  as  hazardous  substances  under   section  102(a),  232
substances  originally listed as Extremely Hazardous  Substances  (EHSs)  under
section 302  of SARA.  Section 102(a) of CERCLA authorizes  the Administrator of
EPA to promulgate regulations designating as a hazardous substance any substance
that, when released into  the  environment, may  present  substantial danger to
public health  or welfare  or the  environment.   The notification and liability
provisions of CERCLA apply only  to substances designated as hazardous substances
under the  statute.   Although EPA may take actions  to  respond to  releases of
pollutants or contaminants that are not CERCLA hazardous  substances , the Agency
cannot recover the costs  of  such response actions pursuant  to  section  107, as
it can in  the  case  of response actions  involving CERCLA hazardous substances.
The proposed rule to designate  the non-CERCLA EHSs was published  in the Federal
Register  on  January  23,  1989  (54  FR  3388).   Currently,  there  are  725  CERCLA
hazardous substances.

     Past and  Ongoing Activities

     On May  25,  1983,  EPA issued an Advance Notice of Proposed Rulemaking (48
FR 23602)  soliciting comments  on approaches  for determining which  substances
should be proposed for designation as hazardous substances under CERCLA section
102(a).  EPA continues to  examine designation approaches  and candidate  lists of
substances;  once  a  methodology has  been prepared for identifying  a candidate
list and for selecting substances from these lists,  EPA will  propose additional
substances for designation in future rulemakings.

     62 Payment of Research Costs Under CERCLA Section 104(i)(5)(D)

     EPA took  no action to implement CERCLA section 104(i)(5)(D).   Under this
section potentially  responsible parties  are  liable  for  the  costs  of  research
under section  104(i).  The  existing  regulations under  the Toxic  Substances
Control Act  (TSCA) and  the Federal Insecticide,  Fungicide and  Rodenticide  Act
(FIFRA)  allow EPA  to  pass  the  major portion  of research  costs  on   to  the
potentially responsible parties.  In  many cases, the costs of research conducted
under these  programs are  already borne  by the manufacturers,  processors,  and
registrants  of the  substances.    EPA,  therefore, has  determined  that  further
regulations  are unnecessary.
                                       93

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
     63 National Contingency Plan Under CERCLA Section 105

     Early in  the  fiscal  year,  EPA began a broad and comprehensive rulemaking
process to revise  and  restructure  the NCP.   The NCP is the primary regulation
directing government and potentially  responsible party response to and  cleanup
of  discharges  of  oil  and releases  of hazardous  substances,  pollutants,  and
contaminants.   CERCLA  section 105 mandates that  the NCP  be revised within  18
months of  the date  of enactment  of  SARA to incorporate statutory revisions
relating to selection  of  remedy.   To carry  out the rulemaking  EPA formed  a
workgroup that included  staff from EPA  Headquarters  and  Regional offices,  as
well as representatives of the  States and other Federal Agencies.  The Agency
formed sub-workgroups for  selection of remedy and State-involvement issues.  The
NCP workgroup  met 16  times  during FY87, and numerous sub-workgroup  meetings were
held.  EPA management  was  briefed  and consulted on a regular basis.   EPA held
its closure meeting covering many parts of the NCP revisions in September  1987.
Closure on  remaining items occurred  in  the first quarter  of  fiscal 1988,  at
which time  EPA consulted  the NRT  as  required by  Executive Order 12580.    The
proposed NCP  was published  in  the Federal Register  in  December  1988  (53  FR
51394).

     The primary purposes  of  the rulemaking is to  incorporate changes mandated
by CERCLA,  as  amended,  and to set forth EPA's  approach for implementing  CERCLA.
In addition, the revisions:

     •    Reorganize the  NCP to  coincide more  accurately  with  the
          sequence of  response actions taken pursuant to  the NCP;

     •    Clarify  existing language on roles, responsibilities,  and
          activities of affected parties; and

     •    Incorporate  changes indicated  by program experience since
          the  last revisions  to the NCP  in 1982.

When the revised NCP is promulgated all existing subparts  will be  revised  (with
some consolidation), and several new  subparts will be added.

     The major substantive  revisions to  the NCP  are  included  in  a  revised
subpart detailing the response process and new subparts on State  involvement  and
the administrative record.  Among the significant issues being addressed in  the
NCP revision are:

     •    Selection of remedy steps and  criteria;

     •    State involvement in response  activities;

     •    The  purpose  of the  NPL;

     •    Compliance with  ARARs; and

     •    Development  of the  administrative record.
                                       94

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     Revision  of  the HRS,  an appendix  to the NCP, also  was undertaken during
FY87.  Discussion of activities  surrounding that revision is included in section
2.3.5 of this  Report.


     6.4  Financial Responsibility Under CERCLA Section 108

     During the fiscal year, the  Office of Solid Waste requested $100,000 from
the Superfund to pursue implementation of CERCLA section 108.   SARA supplemented
the  existing  provisions in  CERCLA  section  108 on  the  proof of financial
responsibility to be required  from owners  and operators  of  vessels and from
other PRPs and on the handling of claims against their guarantors and insurers.
SARA  supplements  CERCLA section  108(b)(2)  to  describe  ways  in  which  the
financial responsibility of those involved with the production, transportation,
treatment, storage,  or disposal of  hazardous substances can be evidenced.  The
President  is   authorized  to  promulgate  regulations   to  implement  these
requirements.

     6.5  Awards Regulations Under CERCLA Section 109(d)

     The Agency published interim final regulations implementing CERCLA section
109 (d) in the Federal Register in May 1988.   SARA amended section 109 (d)  to allow for
the  payment  of  an  award  of  up  to  $10,000  to any  individual who provides
information that  leads  to  an arrest and  conviction of a person for  a criminal
violation under CERCLA.  Section  109(d) authorizes the President to  promulgate
regulations prescribing  criteria  for  these awards.

     6.6  Review  of Denied Claims Under CERCLA Section 112(b)(2)

     Prior  to  the  enactment of  SARA,  section  112(b)(4)  of  CERCLA required
creation of  a Board of  Arbitrators to  review  EPA's  claim determination if a
claim was denied or a claimant disputed the amount of an award.  Section 112(b)
of SARA  revoked the statutory  authority for an arbitration board  and,  in its
place, amended CERCLA 112(b)(2)  to allow a claimant to request  an administrative
hearing if all or part of a claim is denied.  Consequently, EPA on September 8,
1987  (52  FR 33812), withdrew  its  rule  at 40  CFR  305 for  arbitration  and is
currently drafting  a rule for administrative hearings of denied claims.

     6.7  Indemnification of Response Action Contractors Under CERCLA Section 119(c)

     On  October 6,  1987,  EPA  issued  interim  guidance on  indemnification of
Superfund response action contractors (RACs) under section  119 of CERCLA (OSWER
Directive  //9835.S).    The  interim  guidance  contains  general  section  119
indemnification  guidelines  and procedures for  EPA  Headquarters and Regional
contracting personnel and indemnification contract language.  EPA is currently
working on final  indemnity  guidance and plans  to publish (for public comment)
a proposed guidance in  the Federal Register  in  1988.   After  reviewing the public
comments,  EPA plans  to issue  a  final  guidance document and to  promulgate
regulations concerning RAG  indemnification,  as  required by section 119.

     All RACs have had their contracts  modified to reflect the requirements of
section 119.    In addition,  several  contractors  working for States at Superfund
sites have entered into indemnity agreements with EPA, pursuant to section 119.

                                       95

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                 Progress Toward Implementing Superfund: Fiscal Year 1987
     6.8  Reimbursement to Local Governments Under CERCLA Section 123(d)

     On October 21,  1987  an interim final  rule under CERCIA section 123(d) was
published  in the  Federal Register  authorizing  reimbursement  to  local governments.
The costs  incurred  in  providing temporary emergency measures in  response to
releases  of hazardous  substances  can be  reimbursed  for up  to  $25,000 per
incident.  The rule  was published just four days beyond the statutory deadline
of October 17.

     6.9  Natural Resource Damage Assessment Reimbursement Under CERCLA Section 301(c)(l)

     CERCLA section 301(c)(l) authorizes the President to promulgate regulations
prescribing  procedures  for the reimbursement of costs  incurred by Federal and
State  officials  and Indian tribes in  assessing damages  resulting  from the
injury,  destruction, or  loss  of natural   resources.   The  Department  of the
Interior published general,  standardized procedures  under section 301(c)(2)(A)
on March  20,  1987 (52 FR 9042).   Administrative and site-specific procedures
under section 301(c)(2)(B) were published on August 1, 1986 (51 FR  27674).  The
proposed  rule to  provide  amendments  to   the  final  natural  resource  damage
assessment regulations, mandated by SARA and required to be promulgated no  later
than April 17, 1987, was  published on that date  (52  FR  12886) by the Interior
Department.  The final  rule  was  published  on  February 22, 1988 (53 FR 5166).

     SARA section 517(a),  however, amended  the Internal Revenue Code to prohibit
expenditures for the purpose of carrying out those provisions of CERCLA section
111 that authorized claims submitted by Federal,  State, or Indian Tribe trustees
for reimbursement of the costs of assessing damage to  a natural resource, or for
the restoration of a natural resource that had been injured, destroyed, or  lost.
Consequently, on September 8,  1987,  EPA withdrew the rule (40 CFR 306) and the
regulatory  procedures  (40  CFR  305)  it had  promulgated  for evaluation and
submission of natural resource claims  (52 FR  33812).

     6.10 Health and Safety/Worker Protection Standards Under SARA Section 126(a), (e), and (f)

     As required by  SARA  section 126(e), the  Secretary of Labor promulgated in
the  Federal  Register  on  December 19,  1986  (51  FR  45654),   interim   final
regulations  on standards for  the  health  and  safety protection  of  employees
engaged  in  hazardous  waste  cleanup  operations.    By October 17,  1987, the
Secretary was to have promulgated final regulations  under section 126(a), with
an effective date  one  year later.   The Notice  of Proposed Rulemaking appeared
in the  Federal Register  on August  10,  1987 (52 FR 29620);  the final rule was
promulgated  on March 16,  1989.

     Under  SARA  section  126(f),  and within  90  days of  the  final regulations
promulgated by the Secretary of Labor, the Administrator  of EPA must promulgate
identical  standards  for  State and  local government employees not covered by
State plans  approved under section  18  of the Occupational Safety and Health Act
of  1970.
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7.0   DEVELOPMENT AND EVALUATION OF PERMANENT TREATMENT TECHNOLOGIES

     7.1  Overview

     Section 301(h)(l)(D) of CERCLA requires the Administrator of EPA to submit
as  part  of his  Annual Report  to Congress  an  evaluation  of newly  developed
feasible  and  achievable permanent  treatment  technologies.   The  technologies
potentially subject to  such an  evaluation  could range  from those able to treat
source materials to  those  designed to  deal with  contaminated ground  water.
Although EPA does not have a comprehensive  program that systematically monitors
the  commercial  and  research  environment   to  identify   and   evaluate  such
technologies, several important activities are  underway.

     In Superfund1s 7-year history, it has become apparent that a premium must
be placed on the use of permanent treatment technologies in conducting response
actions.   The most common  response  method in use today is land disposal;  yet,
it  is neither completely  reliable nor permanent.  Continued  use of  inherently
temporary  and potentially  unreliable methods  such as  land disposal can  be
expensive and inefficient  over the long run because of the  recurring  need  to
monitor and replace defective waste disposal  containers.  While some alternative
treatment methods are coming into  use, overall,  the development of new treatment
technologies has proceeded very slowly.  SARA included provisions  to encourage
EPA  to  conduct  more  research  and development of  hazardous waste  treatment
technologies.

     During  fiscal year 1987,  EPA took several steps  toward   establishing  a
steady stream of new  treatment  technologies  in  the development  pipeline.   Most
importantly, the  first  demonstration of new treatment technologies  under the
SITE Program was completed, and five more demonstrations are currently planned.

     Also,  other  EPA activities  not  specifically directed towards  technology
development are, nonetheless, generating new technology uses.   These include:

          •    Treatability  studies,  undertaken as  part   of  the
               feasibility  study,  to  determine  the  effectiveness  of
               different remedies;

          •    The  Superfund Technology Support  Project  (STSP), a
               technical assistance program  to encourage the use  of
               new technologies;  and

          •    A survey of treatment technologies used worldwide.

     7.2  Superfund Innovative Technology Evaluation Program Design

     Section 209(b) of  SARA  amends  Title III of  CERCLA by adding  Section 311,
which directs the Agency to establish  an "Alternative and Innovative  Technology
Research and Demonstration Program."  This  Congressional mandate codified EPA's
existing Superfund  Innovative  Technology Evaluation (SITE) program,  which had
been created the year before.   The SITE Program is intended to:   (1)  accelerate
the  development,  demonstration,   and  use  of  new  or  innovative   treatment
technologies; and  (2) demonstrate and evaluate  new,  innovative  measurement and
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monitoring technologies.  Section 311(e) of CERCLA requires  an  annual  progress
report  (at  the  time  of the  annual budget  submission)  on  the  demonstration
program  the  Agency is  conducting.    EPA submitted  its first  SITE report  to
Congress in February 1988.

     There are  five components  to the SITE program.   Three of the  components
concern the development of new treatment technologies:

          •    The Demonstration Program,
          •    The Emerging Technologies Program, and
          •    The Innovative Development and Evaluation  Program.

     Of these three programs, only  the demonstration program was  operating  in
FY 1987.  The Emerging Technologies Program and the Innovative  Development and
Evaluation Program  were expected to  begin operation  in  FY 1988  and are not
discussed in this Report.

     Section  7.2.2 of  this  report  discusses  the  other  two  SITE program
components:

          •    The Measurement and Monitoring Techniques  Development
               Program, and
          •    The Technology Transfer/Clearinghouse Program.

     72.1  Superfund Innovative Technology Evaluation Demonstration Program

     The demonstration program is  charged with finding new technologies that can
meet  the new  cleanup  standards  under CERCLA  requiring  greater reliance  on
permanent remedies.  The program's  main focus is to provide sound engineering
and cost data on selected new technologies to aid in Superfund  decisionmaking.

     EPA uses two methods of identifying SITE participants:

          •    CERCLA section 311(b)(5)(B) solicitations,  and
          •    Evaluation  of technologies  used  by  EPA's  Regional
               offices.

     CERCLA  section   311(b)(5)(B)   requires   the  Administrator   to  publish
solicitations for  innovative and alternative  technologies suitable for  full-
scale demonstration at Superfund sites.  Two solicitations have been issued; the
first on  March  15,  1986 and  a  second on January 15,  1987.   The  technologies
chosen must be at pilot or full scale, be innovative,  and offer some advantage
over  existing  technology.    Mobile  technologies  are  of  particular  interest.
After consultation with EPA Regional staff and the developer, the Agency chooses
for  these demonstrations  sites where  the wastes  would  best  illustrate the
capabilities of  the new technology.

     A second method EPA used to  identify SITE participants was  an evaluation
of  technologies used by  EPA's  Regional  offices during  removal   and  remedial
response actions.
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     Demonstration Program Reports

     Each demonstration program  project  results  in two  final reports:

          •    A technical report that documents the performance data
               resulting  from the  demonstration and summarizes  its
               findings  in terms of effectiveness,  reliability,  and
               cost;  and

          •    A  report  that evaluates  the  degree to  which  each
               technology applies  to  other  sites  and wastes,  the
               limitations  of the process,  and  its economics.   The
               report should provide  the  decisionmaker with  enough
               information to  make  a preliminary decision  as  to
               whether this  process can be used to  treat a  specific
               problem.

     In  general,  both reports   should be  available  6  to 8  months after  the
demonstration is completed.  These reports are distributed to Federal and State
hazardous waste cleanup  offices  and are also available through  the Center  for
Environmental  Research  Information  (CERI)  in  the Office  of  Research  and
Development, and the  hazardous waste collection  in the  EPA  library.

     The Fiscal 1987 Demonstration Program

     EPA  worked with 11  technologies  that were  selected during FY86;  one
demonstration was  completed during the year.  An  additional demonstration  was
completed just after  the close of the fiscal year,  and four  more were completed
during  the  winter  of 1987/88.    Another  five technologies  have not yet been
scheduled for demonstration,  either because a site could  not be  found to match
the technology, the technology is not  at full scale development,  or permitting
requirements have  slowed  the  process.

     Although a twelfth developer, Waste-Tech Services,  Inc., was selected under
the first solicitation to demonstrate  its  fluidized bed combustion technology,
Waste-Tech notified EPA  in July  1987 of its  withdrawal due  to  indemnification
Issues.

     Completed Demonstrations

     Two SITE demonstrations have been completed.   The  first demonstration  was
conducted from July 31 to August 6,  1987, at the Peak Oil Superfund  site in
Tampa,  Florida  (EPA Region 4),  by Haztech,  Inc.,  of  Atlanta,  Georgia.  This
demonstration used  a transportable, 100-ton per day, thermal  destruction system
technology developed  by Shirco Infrared  Systems, Inc.   The Shirco process uses
rows  of electrically powered  silicon  carbide  rods  to bring  the  waste  to
combustion  temperatures   and  then destroys  any  remaining combustibles  in an
afterburner.  The  full-scale  system can process  from 100 to 250  tons of waste
a day, depending on the waste characteristics.

     During the demonstration, EPA SITE staff conducted a trial  burn (three 8-
hour runs)  and  extensive sampling.  All operating conditions during the runs
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were documented.  By mid-October,  the phase of the removal  action  involving  the
use of the Shirco System was completed.  A total  of 7,000  cubic yards of waste
material had been processed.  A final technical report on the  demonstration  was
completed in the summer of  1988.

     The second demonstration was conducted from October 13 to 16,  1987, at  the
Douglasville Disposal Superfund site in Douglasville,  Pennsylvania  (EPA Region
3), by Hazcon,  Inc.,  of Katy, Texas.   A solidification/stabilization process
technology was used in the  demonstration.

     The Hazcon process blends contaminated soil  with  cement, pozzolans, and a
proprietary ingredient  called chloranan,  which aids  in the solidification of
organics.  Solidified blocks  were  returned to the excavation hole and will be
monitored for  integrity over  a  5-year period.   A final  technical report is
scheduled to be completed in the summer of 1988.

     Demonstrations Underway

     •    American  Combustion,  Inc.  of Norcross,  Georgia, completed the
          demonstration of  the Pyretron, an oxygen-air-fuel burner, which
          can be fitted to a conventional rotary kiln.   This technology was
          demonstrated at EPA's Combustion Research Facility at Jefferson,
          Arkansas.  Contaminated soil from the Stringfellow Acid  Pit site
          in Glen Avon, California (EPA Region 9) was  processed.

     •    Shirco  Infrared  Systems  of  Dallas,  Texas,   demonstrated  a
          portable,  one-ton  per  day,  pilot  Shirco  unit  incineration
          technology at  the Rose Township-Demode  Road Superfund site in
          Rose,  Michigan  (EPA Region  5).   The  one-ton per  day  unit is
          similar to the 100-ton per day unit except  for waste capability
          and size.

     •    Demonstration of an in situ vacuum extraction process was completed
          at the Groveland Wells Superfund site in Groveland, Massachusetts
          (EPA Region 1) by Terra Vac, Inc., of Dorado, Puerto Rico.  The
          process consists  of  installing subsurface wells  and introducing
          a negative pressure gradient through the use of vacuum pumps.
          The  resulting air-streams  that  come from  the  wells  are then
          extracted and  pulled through a  separator  device and activated
          carbon for adsorption of the volatile compounds before the vapor
          is discharged to  the atmosphere.   The process has been applied
          to a  wide range  of volatile compounds,  as  well  as organic and
          chlorinated solvents.

     •    International Waste Technologies (IWT),  in conjunction with Geo-
          Con, a deep soil mixing equipment company,  demonstrated an in situ
          stabilization  system at  the General  Electric,   Inc.,  site in
          Hialeah,  Florida  (EPA Region 4).   This project demonstrated a
          system  that  treats waste without  excavation.     The  Geo-Con
          equipment  injects the slurry additive  from  the bottom of the
          shaft of  a hollow earth auger.   IWT claims  the process  ti.es up,
          or   bonds,   organic   and   inorganic   compounds,    creating


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          "macromolecules" in vertical  columns that are highly  resistant
          to acids and other deteriorating factors.

     Technologies Selected from First Proposal Solicitation But Not Yet Underway

     The following five technologies selected  in  FY86 were not demonstrated in
FY 1987 either because a site  had not yet  been  selected,  the  technology was not
yet at full scale, or permitting requirements  slowed the process.

     •    The  Basic  Extraction  Sludge  Technology™  was   developed  by
          Resources  Conservation  Company of  Bellevue,  Washington.    A
          chemical plant-like  process, it  uses  differences in  chemical
          miscibility at  different temperatures  to break down waste  into
          three distinct fractions:  (1) dischargeable  water; (2)  reusable
          oil  and  organics;   and  (3)  dry,   oil-free  solids.     The
          transportable system was used as  part  of an EPA removal  action
          at a Savannah, Georgia, site.  The developer collected  sampling
          and performance data,  which  ORD is evaluating.  If the results
          show the unit is able  to operate at  full  scale, a  demonstration
          will be conducted when a suitable  site  is selected.

     •    Detox  Industries,  Inc.   of  Sugarland,   Texas,  developed  a
          technology  involving  application  of  proprietary,  naturally
          occurring and non-pathogenic organisms for biological degradation
          of contaminants.  The  process involves accelerating the  growth
          of proprietary microorganisms and inoculating them into the waste
          matrix.   The  result  is  a   systematic  biodegradation  of  the
          contaminants over a  relatively short time, usually 2 to 4 months.
          A SITE  demonstration  with Detox  has been proposed  for  an  EPA
          Region 6 Texas Superfund Site.  The Agency is  assisting the State
          of Texas with an investigation of treatment technologies that may
          permanently clean up the site.

     •    A  Westinghouse  Electric  Corporation  transportable   electric
          pyrolyzer unit and a transportable plasma arc unit have also  been
          selected for demonstration.  The transportable electric pyrolyzer
          unit transforms a molten mixture of halogens, metals, and other
          impurities  into  a  vitrified  residue  that  should   be   leach
          resistant.

          The transportable plasma arc unit employs electric arc technology
          that uses high temperatures   to produce  a plasma  from  pumpable
          waste.   The waste is  reduced in an oxygen-deficient atmosphere
          and reforms into hydrogen, carbon monoxide,  hydrogen chloride,
          nitrogen, particulate  carbon, and carbon dioxide.  Currently,
          both units are undergoing development testing at Westinghouse's
          southwestern Pennsylvania facility.  Once these units are ready
          for demonstration, EPA will select a Superfund site.

     •    A Pyrolysis Systems, Inc.  plasma  arc unit designed for thermal
          destruction of  contaminants   was  also  selected.   This smaller
          plasma arc unit, owned by the State of  New York, was intended to


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          treat dioxin-contaminated  sludge from the Love Canal  site.   In
          January 1988, New York State advised EPA that it was withdrawing
          from  the  program  due   to  contractual  support  problems  with
          Pyrolysis Systems.

     •    A circulating fluidized bed combustor from Ogden  Environmental
          Services was selected for demonstration.  This combustor operates
          at  a  higher  velocity  airflow  and  produces  a  much  higher
          combustion  efficiency than a  conventional  fluidized bed.   The
          unit employs  simultaneous  limestone  injection that captures the
          acid gases and eliminates the need for a scrubber.   The unit can
          recover heat  as steam,  electricity,  hot water,  or  hot  air.   EPA
          and  the  State of  California  planned to  use  this  combustor  at
          Ogden1s facility near San Diego, California,  to run treatability
          tests on  several  Superfund wastes.   EPA  was to evaluate these
          tests under the SITE  program.

          EPA and the State of California issued the necessary permits for
          operation  of the  facility.    The  City of  San Diego,  however,
          declined to issue a local use  permit.  Currently,  EPA is working
          with Ogden to find a site on which to demonstrate a transportable
          unit it has developed.

     Plans for Fiscal 1988

     EPA has chosen 10  technologies  to be demonstrated  at Superfund sites from
among  the  proposals  submitted  in  response  to  the second solicitation  for
proposals.   While the first  solicitation proposals  consisted mainly of various
thermal  processes,   these   10  technologies  are  primarily biological  and
solidification/  stabilization  processes.    The  EPA  Regional  offices  have
nominated Superfund sites for the  10 new  technologies, and final site selections
were made in FY88.

     122 Measurement and Monitoring Techniques Development Program and
          Technology Transfer Program

     Two additional components of  the SITE program were developing during fiscal
1987:   the Measurement and  Monitoring  Techniques  Development Program  and the
Technology Transfer/Clearinghouse Program.   Activities  related to  these  two
components are described below.

     The Measurement  and Monitoring Techniques Development Program has four
goals:

          •    To assess the extent  of  contamination at a site;

          •    To supply data and information to determine the effect
               on human health  and the  environment;

          •    To supply data to  select  appropriate  remedial action;
               and
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          •    To monitor the success or effectiveness of the selected
               remedy.

     Through  the Environmental  Monitoring Systems  Laboratory  (EMSL)  in  Las
Vegas,  Nevada,   EPA  has   developed   the  following   monitoring/measurement
technologies.

     •    Immunoassays for toxic substances; and

     •    Fiber optic sensing for in situ  analysis at Superfund sites.

     In  the  immunoassay program  in  FY87,  the  Agency participated  in  the
development  and  evaluation   of  a  monoclonal-antibody-based  immunoassay  for
pentachlorophenol.  Under the fiber optics program in FY87,  resources have been
used to improve the  fiber optic sensor for chloroform.  The latest modifications
will allow  field  measurement of  chloroform concentrations in soil gases  above
contaminated ground water at  lower levels  than  currently used in field methods,
i.e., portable gas chromatography.

     123  Technology Transfer/Clearinghouse Program

     Recognizing  that access  to  treatment  information is essential  to  the
acceptance and use of alternative  technologies, the  SITE program has developed
a Technology Transfer/Clearinghouse Program that will  collect,  synthesize,  and
disseminate technology performance data.   EPA will document  SITE demonstration
results in reports to be made available to Federal,  State, and  private  cleanup
managers  and  other  interested parties.    Existing Agency  operations will be
utilized to implement clearinghouse operations, e.g.,  the RCRA/CERCLA hotline,
the OSWER Technology Transfer Bulletin  Board,  and the EPA library's Hazardous
Waste Collection.

     The clearinghouse has three components:

          •    A Hotline provides callers  with up-to-date information
               on  SITE  projects,  demonstration schedules,  and the
               availability  of the results,  and also  refers callers
               to other sources of information.

          •    An  electronic  bulletin board,   part  of  a  planned
               computerized  data  base  network,  provides  summary
               information   on   the   SITE  projects,  demonstration
               schedules, and results.  Currently, this bulletin board
               is available only  to Federal and  State hazardous  waste
               cleanup personnel.

          •    A collection of reports,  journals,  and other documents
               is  housed  in  the  EPA  library's   Hazardous   Waste
               Collection.  This collection is  available at  EPA's 10
               Regional   and  five   laboratory  libraries.     The
               bibliographic data base is  accessible  using a  personal
               computer.  SITE documents will be added  as they become
               available.


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     EPA is in  the  second phase  of the clearinghouse implementation and plans
to include pertinent data generated by other Agency programs, such as RCRA trial
burn data and ORD's water treatability data base, and other Federal agency and
State hazardous waste cleanup projects.

     73 Treatability Studies

     Treatability studies are used to  evaluate the potential effectiveness of
a technology (or series of technologies) in treating Superfund wastes at an NPL
site.  The studies are conducted as part of some  RI/FSs  at  NPL sites, with cost
and  reductions  in  waste volume,  toxicity,  or  mobility  the primary  factors
influencing an  initial  selection.   For example,  the results of a treatability
study  will indicate  how effective  a  given  technology will be  in treating
contaminated soils.   If the  technology is found effective, it may be proposed
as one of the several remedial alternatives and selected as the final remedy.

     Some  remedies  selected during  fiscal  year  1987  involved  the  use  of
treatment  technologies  based on  information  from  preliminary  treatability
studies collected during the RI/FS.  In these cases, a full treatability study
was  deferred until the remedial design  phase of the project.   The number of
treatability studies conducted during RI/FSs is expected to increase in fiscal
1988.   Expanding  the  application of  existing  technologies complements  the
development of  new technologies,  and increases  the  number of waste treatment
alternatives potentially available to Superfund actions.

     Special Treatability Studies

     At the request of  the Superfund program, the Office of Radiation Programs
(ORP) is conducting two  special treatability studies on radium contaminated soil
from several Superfund sites.  The  studies are designed to  develop and evaluate
several technologies  for  possible  use  in treating radium-contaminated soil at
the Montclair and Glen Ridge Superfund sites.   Two major  projects are underway,
the  Volume  Reduction/Chemical  Extraction  (VORCE)  project  and   the  Volume
Reduction Research project (VORRP).

     The  VORCE  project  consists  of  several  studies  examining   methods  to
significantly reduce the quantity  of radioactive soil that must be disposed of
or shipped  offsite.   Topics being studied  include:   the general chemistry of
soils; the  distribution of  radioactivity in soil particle  size fractions; the
mineralogy  of particles  in selected high-radioactivity fractions; treatment of
larger particles, primarily  with  dilute washing solutions; and treatment with
complexing  agents or high-concentration  acid solutions (leaching)  to remove
radioactivity.   Soils from two New  Jersey  sites are being used for  this project,
which is expected to result in a demonstration program project in mid-1989.  The
studies are being done  at ORP's Eastern Environmental Radiation Facility.

     VORRP  uses the "Tru Clean" process and equipment, a Department of Defense
owned  jig  system,  for  separating soils  by size  and specific gravity.   The
project is being managed by ORP and operated at the  Department of Energy Nevada
Test Site.  Contaminated soil from three NPL sites is being used for the VORRP,
which is expected to be  completed  by mid-1988.
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     7.4  Superfund Technology Support Project

     An  essential complement to  the Increased  development  of new  permanent
treatment technologies  is  an information transfer/technical  assistance  program
to encourage field use of these new technologies.   EPA initiated such a  program
in FY 1987:   the Superfund Technology Support  Project.   The project is designed
to provide EPA personnel,  State  Superfund organizations, potentially responsible
parties, and the public with  technical assistance,  demonstration,  training,  and
information  about  the  best demonstrated technologies  for  application  at
Superfund sites as rapidly  as possible.   The project has six components:

          •    Contractor Assistance;
          •    A High Technology Demonstration and Training;
          •    An Information Clearinghouse;
          •    Rotational  Assignments (to  enable EPA personnel  to
               familiarize  themselves with all aspects  of Superfund);
          •    Site Technology  Reviews;  and
          •    A Superfund  Technology Hotline.

The EPA laboratories at Las Vegas, Nevada,  Ada, Oklahoma, and Cincinnati,  Ohio,
were  given  $750,000  each to launch  the  Technology  Support Project.   It  is
expected that four EPA laboratories will be funded under the  Technology  Support
Project in FY88.

     7.5  International Survey

     To  ensure that  Superfund  sites are  treated  using the  best  technology
available world wide,  EPA has  completed an international  survey of  treatment
technologies.  A  report on the results  of the survey,  The Assessment of International
Treatment Technologies Available for Superfund Application, was prepared and will be  available
to  Regions   and  States.    The  report  identifies  technologies  for possible
licensing and  use  in  the  United States.   These technologies were evaluated on
site during FY 1988.
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8.0   TECHNOLOGICAL AND HEALTH-RELATED RESEARCH AND DEVELOPMENT
      AND TECHNICAL ASSISTANCE

     8.1  CERCLA Authority Related to Research and Development as Amended by SARA

     CERCLA  authorizes  a  comprehensive  Federal research program,  with the
overall  objective  of  improving  the scientific  and  technical  basis  of the
Agency's risk  management decisions at  Superfund  sites.   In FY87,  several new
research programs  were begun  that  address  the need for  better  assessment of
health  risks  posed  by  hazardous  substances  and  the   need   for   treatment
technologies  that  provide  permanent  protection of   human health   and the
environment.  Technical support programs that were developed under  the original
CERCLA were also continued.

     Superfund research, development,  and  demonstration activities at EPA and
other Federal agencies were responsive  to several CERCLA provisioas:

     •    Section 209 of SARA amends CERCLA by adding section 311(b),
          which  authorizes  an EPA  program  of research, evaluation,
          testing,  development,  and demonstration of alternative  or
          innovative treatment technologies that may be utilized  in
          response  actions  to achieve  more permanent  protection  of
          human health  and welfare  and  the  environment.

     •    Section  311(c)  authorizes  EPA   to  conduct   and  support,
          through  grants,   cooperative  agreements,  and   contracts,
          research on the detection,  assessment, and evaluation of the
          effects and risks to human health from hazardous  substances
          and detection  of hazardous substances in the  environment.

     •    Section  311(d)  authorizes  EPA  to establish   up to  10
          hazardous substance research centers  to conduct research and
          provide  training  on the manufacture, use,  transportation,
          disposal,  and management  of hazardous substances and  to
          publish and disseminate the results.

     •    Section  104(i) authorizes a  research  program at ATSDR  to
          develop appropriate methods to determine the health effects
          of hazardous substances frequently found at  Superfund sites.
          The research will also seek to develop  methods to determine
          the health effects  of such substances  in combination  with
          other  substances  (complex mixtures).

     •    Section  311(a) authorizes  a  program at NIEHS  to  develop
          advanced  techniques for  detection  and evaluation of the
          effects of hazardous substances on human health;  methods  to
          assess  the  risks  to human health  presented by  hazardous
          substances;  methods and  technologies  to  detect  hazardous
          substances   in the  environment;   and  basic biological,
          chemical,  and physical methods  to  reduce the  amount and
          toxicity  of hazardous  substances.
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     •    Amended Title  10 of the  United States Code  (Chapter 160,
          Environmental  Restoration)  authorizes  the  Secretary  of
          Defense to carry out a program of research, development, and
          demonstration  with  respect   to   hazardous  waste.     The
          Department  of   Defense   program   is   directed  towards  a
          reduction in the quantities of hazardous wastes; methods for
          treatment, disposal, and management (including recycling and
          detoxification);  identification   of   more  cost-effective
          cleanup technologies; collection  of toxicological data and
          methodology   on  risk  of   exposure;   and   the  testing,
          evaluation,   and   field   demonstration   of   innovative
          technologies.

     Substantial  coordination has  occurred  between EPA  and  the  two  Federal
departments authorized  to conduct  technology research under CERCLA:   HHS and
DOD.  A concerted effort has been made to ensure an integrated Federal research
program and to avoid duplication of effort.

     8.2 Technology Research, Development,  and Demonstration

     82.1  Treatment Technology Evaluation

     Site-Surface Treatment

     For  the  treatment of site surface  contamination, both surface equipment
and in situ  treatment technologies are being  evaluated.    In  FY87,   four  major
processes were addressed:   (1) extraction processes that separate contaminants
from the  media in which they  are  found,  with emphasis  on development of field
systems that minimize costs; (2)  immobilization processes that permanently bind
a contaminant to  the existing  medium or to a modified medium; (3) detoxification
processes that degrade  or destroy contaminants  using biological,  chemical, or
thermal techniques;  and (4) delivery and recovery processes that are needed for
both in situ and surface  treatment.

     Major FY87 accomplishments included:   (1)  the  completion  of a handbook on
treatment  of  hazardous  waste leachate;  (2) evaluation  of  the Mobile  Soils
Washing  System;   (3)  additional  design  modifications  for  the  EPA  Mobile
Incineration System; (4)  preparation of the  EPA Mobile  Carbon  Regenerator for
reactivating  spent  carbon  from  physical/chemical  treatment  systems;  and (5)
development of data  on  CERCLA waste treatment for use  in determining the best
demonstrated available technology under  RCRA.

     Ground-Water Restoration

     Two  alternatives  exist for cleanup  of contaminated ground water:   pump-
treat- recharge and in situ  treatment.   Limited research is being  conducted on the
conventional water  treatment  technologies used  to  treat ground water  that is
pumped  to the  surface,  but  this   research area  may  be reexamined  as  new
technologies  and approaches  are  identified.    A  low level of research  also
continues to examine in situ ground-water restoration techniques.
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     8.2.2  Personnel Protection

     Personnel  protection research  is  directed at  specific  safety  and  cost-
efficiency concerns related to use of chemical-protective clothing,  equipment,
and procedures.   Research priorities for FY87  and FY88 were established at a
workshop attended by  EPA Regional offices,  EPA Occupational Health  and Safety
staff, and Superfund contractors.  In FY87, tests  were  conducted on  techniques
for in-the-field assessment of clothing degradation,  decontamination and reuse
procedures, use of personnel coolers  to reduce worker heat stress, problems with
disposable clothing, and use of robotics  and automation.

     Interagency coordination is  enhanced  by a Memorandum of Understanding among
EPA, the Coast Guard,  the National Institute for Occupational Safety and Health,
the Occupational  Safety and Health  Administration,  and the Federal Emergency
Management Administration.

     823  Superfund Research Grants

     In FY87,  EPA established a university research grant program  to  conduct
applied research relevant to  Superfund  site  assessment and  cleanup.    Grant
applications were solicited in two areas:  "Measurement and Monitoring  Methods
for use at Superfund  Sites" and  "In Situ  Treatment of Hazardous Waste."   In the
monitoring area, 20 applications  were received and 9 projects were selected for
funding, including development of rapid screening techniques, more comprehensive
testing protocols,  and  detection  methods  that can be used  with  field-portable
equipment.   In the  treatment  area,  46 applications were submitted  and 5 were
selected for funding.  A range of treatment techniques  are  involved, including
biological treatment that focuses on  chlorinated organic compounds,  polyaromatic
hydrocarbons, and arsenicals.   EPA funded five  additional applications received
in the general  grants program.

     83 Health-Related Research and Development

     CERCLA authorizes significant new health research programs in EPA and HHS.
Although the  statute  does not clearly differentiate among research areas and
agencies in the health research area, a broad  research agreement was  reached on
the scope of each agency program.   The  EPA research program will  focus on the
development and evaluation of toxicological  test methods,  exposure  assessment
methodology, and  risk assessment and characterization techniques.   The  ATSDR
will conduct research  related to its health assessment responsibilities  under
CERCLA.  The NIEHS  will support  multidisciplinary biomedical  research  through
grants to universities.

     83.1  EPA Health Effects, Risk Assessment, and Detection Research

     The  Program's  objective is  to  improve   the  scientific  capability  for
detecting, assessing, and evaluating the  effects on and risks  to  human health
from hazardous  substances, as  needed for Superfund removal and  remedial  cleanup
decisions.

     The EPA research program has been developed  cooperatively  within  ORD and
between ORD  and OSWER.   It has several components  organized conceptually in a
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matrix.  Three of these components correspond  to the steps  in  the Public Health
Evaluation Process used by  the  Office of Emergency and Remedial Response:

     Toxicity Assessment

     Key toxicity data will be  developed for use in risk assessment, including
rapid  response toxicity  testing and field  screening of  priority compounds,
evaluation  of  the  toxicity  of incinerator  and  other   treatment  residues,
evaluation of  PCB  and PCDF carcinogenicity,  and human reproductive risks from
chemical mixtures.

     Exposure Assessment

     To  improve  the  confidence and  accuracy  of human exposure  estimates at
CERCLA sites,  this research will  characterize parameters  needed for exposure
assessment,  validate existing  models,  and develop  approaches  for  assessing
multimedia exposure and integrating exposure assessment.

     Risk Characterization

     Methods  for  characterizing health risks and  environmental effects  of
chemical mixtures  will be  developed and assistance  will be  provided  in site
assessment.

     The  other components  correspond  to  major  research  themes  of  priority
interest to ORD and OERR:

     Internal Dosimetry

     To better predict delivered dose, two areas of  research will be emphasized:

     1.  Pharmacokinetics

     This  initiative will  better  predict   the bioavailability  of chemicals.
Research  will:    define   rates  of  skin,   inhalation  and  oral  absorption;
characterize pharmacokinetic parameters of uptake, distribution, and metabolism;
develop  physiologically based  pharmacokinetic models  for multiple  routes of
exposure and for multiple compounds;  and identify sensitive subpopulations.

     2 .  Biomarkers of Exposure and Effect

     This initiative will focus on methods for  measuring dose through different
biologic assays,  including  a  variety of  somatic  (mutagenicity)  and germinal
markers (sperm measures) as well as the application of markers to epidemiologic
methodologies  to  improve   sensitivity   and  specificity  for  human  disease
endpoints.

     Chemical Mixtures

     Focus will be on developing toxicological models to  predict interactions,
identifying  classes  of contaminants  that may yield additive,  synergistic or
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antagonistic responses, and  developing statistical  methods for analyzing high-
dimensional data sets.

     Noncancer Health Effects

     Reproductive toxicity is a critical endpoint of interest  for OERR and will
be  the  initial  focus.   Research will  develop  sensitive  test  methods   for
detecting  effects on  male  and female  reproductive  systems,  and biological
markers  as early  indicators of  exposure  to  chemical  mixtures.   Additional
emphasis is being placed on neurotoxic  endpoints with  development of new  and
more sensitive in vitro and in vivo endpoints.

     The research projects  vary   in  length from two  to  five years.   Annual
progress reports or program  reviews will be prepared for these projects.

     8.3.2 Agency for Toxic Substances and Disease Registry Research and Development Program

     The ATSDR research program focuses on  assessing  the  relationship between
exposure to toxic  substances and  resulting human health  effects,  and also on
effective ways to inform the public of health  risks.

     Epidemiologic and Pilot Studies

     An  epidemiologic  study  is  the  evaluation  of  a  specific  hypothesis
concerning the relationship between an exposure to a hazardous substance(s)  and
a health outcome  in a  defined population.   All studies  in FY87 were conducted
by the Center  for Environmental Health  and Injury  Control or by the National
Institute  for Occupational  Safety  and Health,  of  the  Centers  for  Disease
Control.

     Fifteen epidemiological studies  were conducted or  in progress on dioxin,
PCBs,  lead, arsenic, volatile  organic compounds, and other  substances.   Also,
nine  pilot   studies,   which  are  used  to  determine   if   a  comprehensive
epidemiological  investigation  is  warranted, were  completed in  FY87,  and five
additional pilot studies are in progress.

     Health  Surveillance Systems

     A health surveillance  is the  periodic  medical  screening of  a defined
population for a specific disease or biological markers  of a disease, for which
the population is at  significantly  increased  risk.   The  surveillance system
should include a  mechanism  to  refer  to for  treatment  of those individuals  who
screen positive for the disease.

     State  agencies  operated  four  health surveillance  systems  in FY87  to
determine the impact of hazardous  substances in the  environment on:   (1) chronic
diseases;  (2) developmental disabilities;  (3)  low  birthweight  and  adverse
reproductive outcomes; and (4)  tracking workers previously  employed, by the Drake
Chemical Company plant in Lock Haven,  Pennsylvania, for bladder cancer.
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     Toxicological Profiles and Testing Needs

     CERCLA section 104(i)(2)(A)  requires publication of a priority  list of 100
hazardous  substances  found  at NPL  sites  that  pose  significant  human health
risks.   ATSDR and EPA published  the list  of the first  100 priority hazardous
substances  in a Federal Register  notice  (52 FR 12866)  and proposed guidelines for
developing  the  first 25 Toxicological  Profiles,  effectively meeting the April
17,  1987 deadline.    On  October  15,   1987,  the agencies published  25  draft
toxicological profiles for  EPA and they are now undergoing public comment.

     A toxicological profile involves an analysis of available  toxicological and
epidemiological  data  to determine health effects from exposure to a substance.
The profile will determine if there  are adequate  data to  set levels  of exposure
that cause health risks, and if not,  will identify toxicological tests necessary
to determine  that level.   EPA and the Hazardous Waste  Information Evaluation
Subcommittee of HHS nominated 50  chemicals and several chemical mixtures to the
National Toxicology Program (NTP) for toxicological testing.   The NTP initiated
testing  of  the  chemicals,  using  Superfund monies,  to fill gaps in  information
about the health effects of the chemicals.

     Human Exposure Assessment

     To  determine the  baseline  amount  of soil that children normally ingest, a
human exposure  assessment study  applied standard  formulae  to measurements of
trace elements found in the stool specimens of small  children.  This study will
support  development  of human exposure assessments,  especially  among children
residing near sites that have contaminated soil.

     Information Dissemination Research

     ATSDR  is  developing,   in  collaboration  with  the  National   Library  of
Medicine, an artificial intelligence expert system for use in emergency response
situations.  The objective of the system is to  provide assistance to emergency
responders to verify,  retrieve,  and  integrate information, to "reason" in some
fashion, to make choices,  and  to build a  precedent  file of  experiences.   The
system will also be used to facilitate training.

     Clinical Toxicology

     A wide range of  clinical toxicological research was conducted  in FY87 on
both  organic  and  inorganic  toxicants, with  specific  programs  to  study  the
effects on genes, the  liver,  the  immune system,  and the kidney.

     Health Education Research

     During  FY87,  ATSDR  supported  research  with  the  National  Academy  of
Sciences,   National   Research   Council,  on   environmental  toxicology   and
environmental  epidemiology,   including a   project  on  risk  perception  and
communication.
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     8.4 Technical Assistance Provided in Fiscal Year 1987

     8.4.1  Chemical Fate, Transport, and Ecological Effects

     During FY87, ORD provided technical assistance to EPA Regional offices and
the Environmental Response Team,  including:  (1) application of a bioassessment
protocol to determine bioavailability of hazardous substances in site samples;
(2) evaluation of  the  efficacy of various disposal  scenarios for contaminated
marine sediments;  (3) evaluation of  ground-water plume movement arid biological
stabilization of subsurface contaminants;  (4)  assessment of contaminant uptake
by fish in  the Great Lakes;  and  (5)  assistance  to  other Federal agencies with
waste problems at  specific Federal  facilities.

     8.42  Site Risk Assessments

     The Office of Research and Development provided assistance to EPA Regional
offices and the  Office of Waste Programs  Enforcement  on  the  assessment of
exposure,  health effects, and  risks.   ORD  provided Endangerment Assessments on
20  sites.   A group  was established to  provide review of  risk assessments
prepared by the EPA Regional offices and to serve as a focal point for obtaining
risk assessment information.

     8.43  Chemical Assessments

     In FY87,  ORD  began work on 50  Health  and Environmental Effects Documents;
15 were completed.  ORD assisted ATSDR in preparing Toxicological Profiles.  In
addition,   12  rapid response  health  assessments on  specific  chemicals  were
provided for use in emergency situations.  RQ documentation for carcinogenicity
and other chronic  health effects were prepared for 50 chemicals and wastes, in
addition to draft RQ documentation for 191  suspected carcinogens  on the original
CERCLA hazardous substances list.  Chronic toxicity profiles were prepared for
74 additional chemicals.

     8.4.4  Engineering Reviews and Assistance

     Engineering  staff  served on technical advisory  committees,  reviewed site
assessment and feasibility plans, and advised on engineering issues.  A report
was completed on data  requirements  for remedial  action technology screening,
evaluation, design, and construction.  In concert with several Regional offices,
EPA  developed engineering  cost  models that  will improve  cost  estimates of
remedial action alternatives.   Regional offices were provided with engineering
assistance for approximately 35 sites, including the feasibility  of using mobile
treatment systems  for specific cleanups.

     8.4.5  Monitoring Support

     Monitoring technical support was provided to EPA Regions and the National
Enforcement  Investigation Center on more than 400  sites.   Remote sensing,
including  topographic  mapping and aerial  imagery was  used to  locate  old or
buried contamination sources  and to create topographic maps.  Approximately 30
maps and  400  images were provided  in FY87.   Advice on  the  use of geophysical
tools, such as  resistivity,  magnetometry, ground-penetrating radar, and other
remote sensing devices, was  provided  in response to  specific requests, as was


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assistance  on  the  proper design  and quality assurance  for sampling protocols.
Performance  of the EPA Regional  laboratories was evaluated  through the use of
reference materials  and  the review of laboratory  data.
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9.0   EPA AND AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY
       HEALTH-RELATED ACTIVITIES

     9.1 Overview of the Health Assessment Program

     To clearly  delineate  the nature of  its  activities,  the Agency  for  Toxic
Substances and Disease  Registry has established the  following  definitions  for
three of its key functions:

     •    The ATSDR  health  assessment is the evaluation of  data  and
          information  on the  release of toxic  substances  into  the
          environment in order to assess any current or future impact
          on public health, develop health advisories or other health
          recommendations,  and  identify  studies or  actions needed to
          evaluate and mitigate  or prevent human health effects.

     •    The ATSDR  health  consultation is a response  from  ATSDR to
          a  specific question  or specific  request for information
          about  a  toxic  substance or a facility affected by a  toxic
          substance.  A health consultation is a more limited  response
          by ATSDR than what  is  provided  by  a health assessment.

     •    The ATSDR health advisory is a communication from the ATSDR
          Administrator to  the  EPA Administrator that states ATSDR1s
          concern  that a public  health  threat  exists that  is of such
          importance   and   magnitude   that   EPA  should  intervene
          immediately.  ATSDR  issued  no health advisories  in FY87.

     There are  purposeful  differences between ATSDR's health  assessments  and
EPA's  risk assessments.  The former are usually qualitative and  site-specific
and  focus on  medical  and  public  health  perspectives.    However,  EPA  risk
assessments  are quantitative  and  use  statistical  and biological  models  to
calculate numerical  estimates of current and  potential risk to  human  health.
EPA's risk assessments may  also  address  environmental  effects.

     92 Progress in Fiscal Year 1987

     In FY87, ATSDR established, as one of its primary goals, the use  of health
assessments  to meet  as many public health needs as  possible.  Toward  this end,
ATSDR  began  the following  activities in FY87 and  continued these activities
through FY88:

     •    Reviewing health assessment data gathered through such means
          as  exposure  surveys,  epidemiological  studies,   exposure
          registries,  and  health surveillance to determine  the need
          for public health followup;

     •    Reviewing  health  assessment  data  to  identify  gaps  in
          knowledge  (e.g.,  toxicity  information)  to guide  research
          efforts;

     •    Establishing  closer working  relationships with State  and
          local agencies to obtain health-related data not  previously

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          supplied to ATSDR and to support State efforts in addressing
          the public health  issues  associated with toxic substances;

     •    Developing a computer-based information system to store and
          manage the health  assessment  data base;  and

     •    Exploring the effectiveness of computer models and graphics
          in research related  to health assessment activities.

     Health Assessments

     ATSDR published,  in the Federal Register,  procedures for requesting  a health
assessment.  These procedures  include minimum requirements for  a petition.   In
addition, ATSDR and EPA jointly issued a procedural manual on conducting health
assessments.  The manual is  designed to integrate  health assessment provisions
of CERCLA into the remedial  program.

     Health assessment-related accomplishments include:

     •    Sixty health assessments  of NPL sites  in 28 States;

     •    Forty-five health assessments of non-NPL  sites in 21 States;

     •    One  health  assessment  as  a result  of  an  individual's
          petition of ATSDR; and

     •    Cooperative agreements were  awarded to  Colorado,  Florida,
          Iowa, Massachusetts,  Michigan, Minnesota, New Hampshire, New
          Jersey, New York,  South Carolina,  and  Wisconsin, to assist
          them in building capacity to  perform health assessments.

     Health Consultations

     There were 1,467 health consultations completed  in 50 States and in Puerto
Rico, the Virgin Islands,  the  District of Columbia,  American Samoa, Guam,  the
Trust Territory of  the Pacific, the  Marshall  Islands,  Palau, Ponape,  Quebec,  and
Mexico.
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10.0  IMPLEMENTATION OF THE FEDERAL FACILITIES REQUIREMENTS

     10.1 Overview of the Federal Facilities Program

     CERCLA section  120, added  in its entirety by SARA.,  states  that,  with few
exceptions, CERCLA  provisions,   guidelines,  rules,  regulations, and  criteria
apply to facilities  owned  and/or operated by  the Federal government,  just as
they do to other facilities.  To focus attention on  these Federal  facilities,
and to  implement the CERCLA requirements  concerning  them, EPA  established the
Federal  Facilities   Compliance  Task  Force   in  the  Office  of  Waste  Programs
Enforcement (OWPE).  The  Task Force  works with EPA  Headquarters and  Regional
offices and States to  resolve issues concerning Federal  facilities.   The goal
of the Task Force is to establish a nationally consistent enforcement program
that recognizes  and  encourages the full use  of  EPA and State  enforcement tools
to ensure that Federal  facilities comply with CERCLA  and RCRA requirements.

     OSWER is also creating a division within OWPE to  monitor  compliance with
environmental laws at Federal facilities.  The division will focus on management
of  the  Federal  facilities  docket,  policy  and  guidance   development,  and
compliance monitoring.

     102 Federal Facilities  Hazardous Waste  Compliance Docket

     CERCLA section  120(c)  requires  EPA  to  establish  a  Federal  Facilities
Hazardous Waste  Compliance  Docket.   The purpose of the docket is three-fold:

     •    To identify Federal facilities that may be contaminated with
          hazardous  substances;

     •    To  compile and maintain  information submitted to EPA  on
          these  facilities  under  the provisions  of  CERCLA  section
          120(c); and

     •    To provide a  mechanism to make this  information available
          to the public.

     The initial docket was published in the Federal Register on  February 12, 1988,
and lists 1,094  Federal facilities;  Exhibits 10.2-1  and  10.2-2  illustrate the
numbers of facilities on the initial  docket by Federal agency and by EPA Region,
respectively.   This  docket, available for public  inspection,  will also contain
notice  of  all actions  taken under  CERCLA   regarding Federal hazardous waste
facilities  and  all  hazardous   substance   release   notification  Information
concerning Federal  facilities submitted to  EPA under  CERCLA section  103 and
under the permitting  and activity notification provisions  of RCRA sections 3005,
3010, and 3016.

     EPA will also  furnish information to the  public  regarding  facilities on
the docket.   EPA has established information  repositories in all  10  Regions.
Each Region  will collect  the documents  submitted by Federal  facilities and
organize and  index  them according to  a uniform system.  A milestone  tracking
system will be developed to indicate each facility's progress in complying with
Superfund and RCRA requirements.
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                             Exhibit 10.2-1
               Federal  Facilities Listed  on  the
       Initial  Hazardous Waste Compliance  Docket1
Department Number of
or Agency Facilities2
Defense
Air Force
Army
U.S. Army Corps of
Engineers
Navy
Other Defense Agencies
Interior (including Bureau of
Land Management)
Energy
Transportation
Agriculture
Health and Human Services
General Services Administration
National Aeronautics and Space
Administration
Environmental Protection Agency
Tennessee Valley Authority
Veterans Administration
Postal Service
Commerce
Justice
Labor
Treasury
Central Intelligence Agency
Housing and Urban Development
Total
574
118
235
15
205
21
254
45
45
26
21
20
16
16
15
14
11
11
2
2
1
1
1
1,094
Percentage
of Totalr
54.3

23.2
4.1
4.1
2.4
1.9
1.8
1.5
1.5
1.4
1.3
1.0
1.0
0.2
0.2
0.1
0.1
0.1
100.1
'53 FR4280, February 12, 1988.

The numbers of facilities may vary in subsequent listings because further information may change a
facility's status.

'Rounding causes percentages to total slightly more than 100.00 percent.
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
                                 Exhibit 10.2-2
                 Distribution  by Region of Federal Facilities
                on the Hazardous  Waste  Compliance Docket
Region
1
2
3
4
5
6
7
8
9
10
Total
*Rounding
percent.
Number of
Facilities
50
98
127
127
89
98
32
74
240
159
1,094
causes percentages to total
Percentage
of Total*
4.6
8.9
11.6
11.6
8.1
8.9
2.9
6.8
21.9
14.5
99.8
slightly less than 100.00
     EPA's efforts  in establishing the  docket  in coordination with  the other
Federal agencies and departments involved compiling data to produce the initial
docket of Federal facilities and setting  up repositories in EPA Regional offices
to hold the collected information.   Compiling and verifying the  data required
extensive coordination between EPA Headquarters, Regional  offices,  contractor
staff, and other Federal agencies. EPA expects  to publish an updated docket in
the Federal Register  every 6 months.

     103 Federal Facility Preliminary Assessments/Site Investigations

     Executive Order  No. 12580  delegates the  responsibility for conducting PAs
and Sis at Federal  facilities to the Federal agencies  that  own and/or operate
those facilities.   EPA has the responsibility to ensure  that these activities
are performed and has provided guidance and training and organized workshops for
other Federal departments and agencies on conducting PA/SIs.  To address CERCLA
deadlines, EPA developed a  strategy for pre-remedial  activities that  set an
April 17, 1988,  deadline  for Federal agencies to submit  to  EPA a PA report on
each of the facilities listed on the  initial  Federal  facilities docket.

     This initial assessment will help  determine if a  release  has occurred or
if there is a  significant  threat of  a release,  and  whether the facility should
be evaluated  for inclusion  on  the  NPL.   Thus,  the docket  is  not intended to
serve as an NPL  for  Federal  facilities.   When the PA  indicated that additional
evaluation of the  facility  was necessary  and the PA  data was  inadequate to
support an HRS evaluation,  EPA requested the  responsible  agency to provide, by
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April 1988,  all  the information necessary to perform  a  full HRS evaluation of
the site.   EPA will propose such  facilities for inclusion  on the  NPL if they
meet the established criteria.

     10.4 Federal Facilities Proposed for and Listed on the National Priorities List

     On July 22,  1987,  EPA added  32  Federal facility sites  to  the  NPL (52 FR
27620),  the first Federal facilities to be included on  the  list.  One additional
Federal  facility was proposed  for inclusion  on the  NPL, pending  a complete
review of comments and the resolution of technical and policy  issues.  Fourteen
additional Federal facilities were proposed  for the NPL on June 24, 1988; later
in 1988 a proposal  specifically for Federal  facilities will be published.

     10.5 Federal Real Property Transfer Regulations Under CERCLA Section 120(h)(l)

     Anytime  the Federal government  sells  real property  at  which  a hazardous
substance was  released,  disposed of,  or  stored for a year  or more,  the sales
contract must include a  notice that  discloses the type  and quantity  of the
hazardous  substance and  when  it was  on the property.    Additionally,  CERCLA
section  120(h)(3)  requires  any   Federal department  or  agency  transferring
federally owned  real  property to  include  in the deed a covenant  assuring the
transferee  that  all remedial  action necessary  to protect  human health and the
environment was taken before the transfer, and also that the Federal government
will conduct any remedial action  found to  be necessary after the  property is
transferred.

     Section  120 also  requires EPA to promulgate regulations on  the form and
manner of the notice to be put in sales contracts and deeds.  EPA proposed these
regulations  on January 13,  1988.   Among the proposed  rule's key provisions is
the requirement that the contract notice contain the hazardous substance's name
and Chemical Abstracts Service Registry Number,  and the time  and quantity of its
storage, release, or disposal.  The Agency will also  propose that the transfer
of some  single-family residences  acquired  through foreclosure by  government
agencies such as the Federal Housing Administration and Veterans Administration
be exempted from the notice  requirement.   Property  at  which less  than 1,000
kilograms of hazardous substances  were stored would also be exempt.

     10.6 Interagency Agreements  Under CERCLA Section 120(e)(2)

     EPA,  the  Department of the Army, and  the  State  of  Minnesota  signed the
first interagency agreement (IAG) involving a Federal facility, the Twin Cities
Army Ammunition Plant, on August 12, 1987.  The final decision on the remedy to
be undertaken  at a Federal  facility is made  jointly by EPA and the responsible
agency,  unless there is disagreement,  in  which  case,  EPA has authority to make
the decision unilaterally.  Agreement  on  the selected remedy is outlined in an
IAG between EPA  and the responsible Federal  agency.

     EPA views an IAG as  a  comprehensive  document  that addresses all hazardous
waste activities that will  be  conducted at a Federal  facility,  from the RI/FS
through the implementation of the remedial action.  lAGs formalize the procedure
and timing  for submittal  and review of documents and  establish  a  mechanism to
resolve disputes.  lAGs must comply with  the public participation requirements
                                      119

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


of GERCLA section 117,  and  they  are  enforceable by citizens and States through
citizens suits.  Additionally, CERCLA authorizes assessment of civil penalties
against Federal agencies  for  failure to comply with lAGs.

     10.7 Report to Congress on EPA Responsibilities Under CERCLA Section 120(e)(5)

     EPA has 14 facilities subject to section 120(e)(5) reporting requirements.
This number differs from  the  number  of EPA facilities listed in Exhibit 10.2-1
due to changes in facility  status  that occurred after the  original Federal Register
notice was  published.   These 14 facilities are  identified  in Exhibit 10.7-1.
Section 120(e)(5) requires each Federal department, agency, and instrumentality
to  furnish  an annual  report   to  the  Congress  concerning  its  progress  in
implementing CERCLA at  its facilities.  The report must include information on:
progress in reaching interagency agreements; cost estimates for each IAG; public
comments on lAGs; progress in RI/FSs and RAs initiated at Federal facilities on
the NPL; and progress in  RAs  at  non-NPL facilities.

     The Occupational Health and Safety staff of  EPA's Office of Administration
and  Resources  Management  is working to  prepare  the  report  on   these  EPA
facilities.   At present,  these facilities  are  undergoing  PAs;  consequently,
there are no RI/FSs or  other  remedial actions to report as yet.
                                       120

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                 Progress Toward Implementing Superfund: Fiscal Year 1987
                                    Exhibit 10.7-1
                              EPA Facilities on the
                    Hazardous Waste Compliance Docket
Facility/Location
   EPA ID #
Region
Narragansett Environmental Research Laboratory
Narragansett,  Rl

Environmental Services Division Laboratory
Edison, NJ

Environmental Photographic Interpretation
  Center
Warrenton, VA

Environmental Services Division Laboratory
Annapolis, MD

Environmental Research Facility
Gulf Breeze, FL

Andrew W. Breidenback Environmental
  Research Center
Cincinnati, OH

Center Hill Hazardous Waste Engineering
  Research Laboratory
Cincinnati, OH

Environmental Services Division Laboratory
Chicago,  IL

Testing and Evaluation Facility
Cincinnati, OH

Combustion Research Facility
Jefferson, AR

Environmental Services Division Laboratory
Kansas City, MO

EPA Mobil Incinerator
Denny Farms, MO

National Enforcement Investigation Center
Denver, CO

Environmental Services Division Laboratory
Manchester, WA
RID 075721639


NJD  1680090015
OH 2680030929
OH 1680090007
AR 6140090006
MO 6680090010


CO 1680090031
   1



   2



   3




   3


   4


   5
   5


   5


   6


   7
   8



   10
                                        121

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


11.0  MINORITY FIRM PARTICIPATION IN SUPERFUND CONTRACTING

     The 1986 enactment of SARA added to  CERCLA a new provision, section 105(f),
that requires that the availability of minority businesses be considered in the
Superfund work carried out under contract  to  the  Federal government.

     In the fulfillment of this mandate,  EPA's Office of Small and Disadvantaged
Business Utilization (OSDBU)  has continued  and expanded existing programs, begun
new  activities,  and planned additional efforts  to ensure  the  full  and fair
consideration of minority  firms for Superfund  contracting.    EPA meets  the
remainder  of  its section  105(f)  responsibilities  by  describing  its  minority
contracting program activities  and results in this  Report.

     11.1 EPA Procedures to Identify Qualified Minority Firms

     EPA employs a  wide variety of procedures to identify minority firms that
may  qualify  for  work  as  Superfund  prime   contractors  or  subcontractors.
Contractors must meet standards of technical  and  financial  ability in order to
qualify  for Superfund  work.   These procedures,  which usually   involve  the
assistance of minority business agencies  at the Federal, State, and local level,
are discussed below.

     Memorandum of Understanding  with the Minority Business Development Agency (MBDA)

     One of the  tools  EPA  can use in  its implementation of the Superfund program
is a Memorandum of Understanding (MOU) .   An MOU is a statement agreed to by two
or more parties  (in this case,  EPA and another  Federal  agency)  that recognizes
the  interrelationship  of   their  two   functions  and   specifies   appropriate
interactions between the two parties.  EPA is  negotiating an MOU with the MBDA,
a unit of the U.S. Department of Commerce,  to gain its assistance in identifying
minority business  enterprises  (MBEs) that may be  eligible for  work  in  the
Superfund  program.   Minority  business development  centers  (MBDCs) ,  which  are
private firms that  assist the  Federal  government in its minority contracting
efforts, will be particularly helpful in  this  effort.   EPA envisions several
ways  to use MBDA  regional  offices  and MBDCs  to match  minority  and women's
business enterprises  (WBE) with specific  Superfund direct  procurement needs.
For example, MBDCs can provide technical  assistance needed by firms  to help them
qualify for Superfund contracting.

     MBE Coordinators in EPA Regional Offices

     EPA employs MBE Coordinators in each  of  its  10  Regional offices to act as
liaisons between OSDBU  and EPA Regional personnel,  State and local officials,
MBDA Regional offices,  and MBDCs.  Special  efforts have been  made to apprise MBE
coordinators of the requirements for  Superfund minority contracting and how they
may  assist  EPA's   Superfund  program  officials   in   complying   with  these
requirements.

     Survey  of State and Local Governments

     EPA has begun a survey of State and local governments to determine whether
these  governments  have  established goals  or objectives   for  minority  firm
participation in government  contracting.   EPA will use  the results  of this

                                      122

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


survey, which  is targeted  for  completion in  FY88,  to  inform  State  and local
government offices of the Superfund minority contracting program.  In a related
effort, EPA's Regional  MBE Coordinators will  solicit information on potential
Superfund minority contractors  from  State  governments  in their Regions.

     Small Business Administration (SBA) Section 8(a) Program

     EPA's Socioeconomic Program  Officer  will work closely in  FY88  with SBA
officials to identify any  Superfund  contracting needs  that may be fulfilled by
minority contractors in  the SBA section 8(a)  program.   The 8(a) program, which
was established by section  8(a) of the  Small Business Act, allows SBA to act as
a prime contractor for  Federal  government contracts and set up subcontracts with
small disadvantaged (minority)  firms.  The  small disadvantaged firms compete for
these subcontracts only  against other such firms  in  the 8(a) program.

     EPA Procurement History Files

     EPA will undertake a comprehensive search  of its Procurement History Files
in FY88 to identify minority firms that have worked on Superfund projects in the
past.

     The MBDA PROFILE System

     The MBDA maintains  a computer-based compilation of  data  on approximately
31,000 minority  firms known as the PROFILE System.  The system classifies firms
according to  Standard  Industrial  Classification  Code  and Zip  Code.   Minority
businesses listed in another data base, the  SBA's Procurement Automated Source
System  (PASS), have been extracted from PASS  and incorporated into the PROFILE
System.  EPA will undertake a  search of the  PROFILE  system in FY88 to identify
potential Superfund minority contractors.

     11.2 EPA Efforts to Encourage Participation

     Because Superfund contracting opportunities are not always well known, and
because entry  into  a Superfund  contract is  voluntary,  EPA  must  publicize the
Superfund minority contracting  program in  the minority  business community, and
must encourage the participation of qualified firms.   This subsection describes
the various ways in which EPA brings  qualified firms into the Superfund minority
contracting program.

     Minority Procurement Conferences

     In a collaborative  effort  with  EPA's  Procurement  and Contracts Management
Division, OSDBU  has sponsored  several highly  successful  Minority Procurement
Conferences  in  various   locations throughout  the  country to help  minority
businesses  participate  more fully   in the   Agency's  competitive  procurement
activities.  Two of these  Conferences were held in FY87;  three are planned for
FY88.

     MBE/WBE Information Seminars

     EPA and  State  governments  co-fund State-run seminars  to  inform minority
firms  of  EPA contracting  opportunities.   Three seminars  (one each  in Utah,

                                       123

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


Florida,  and Washington)  were  held.    In  FY88,  seminars have  already  been
conducted in Mississippi and New England,  and are scheduled for Oregon and New
York.

     OSDBU MBE/WBE Training Workshops

     OSDBU  conducts MBE/WBE  Training  Workshops  for EPA Regional  and  State
officials; workshops were held  in four  EPA Regions that involved 23  States and
the  District  of Columbia.   Workshops  for the  remaining  six  EPA  Regions  are
scheduled for FY88.  An Annual  Workshop for OSDBU Regional MBE Coordinators is
also held.

     Minority Business Training

     In FY88, EPA will assist the National Association of Minority Contractors
(NAMC) in conducting training programs to prepare potentially qualified minority
firms  to compete  more  effectively  for  EPA and  State  prime  contracts  and
subcontracts.  Three weeks of training  activities will be  conducted  in each of
several  major  cities through  a  $500,000  contract awarded to NAMC  by EPA on
January 14, 1988.

     MBDA National and Regional Conferences

     MBDA, by agreement with  EPA, conducts  national and Regional conferences for
MBDCs to encourage minority businesses  to participate  in the Superfund program.
One national  conference  and one  conference in each MBDA  Region are;  conducted
each year.

     Letters to Other Federal Agencies Participating in the Superfund Program

     OSDBU  stressed the  importance of minority contractors   in  October  1987
letters  it  sent to  its counterpart  OSDBU offices  in other  Federal  agencies
involved  in the  Superfund program,  such as  the Army Corps of Engineers.   In
order to help ensure that these other agencies comply with section 105(f),  EPA
has required  them  to submit regular,  detailed  reports  on Superfund  contracts
they have awarded to minority firms.

     Publications on Superfund Participation

     EPA  issued  two publications  on  contractor participation in Superfund in
FY87:  "CERCLA:   Getting into the Act," in April 1987, and  "Doing Business with
EPA," in August 1987.

     113  Participation by Minority Firms in Superfund Contracting

     The  extent  of minority  Superfund  contracting  relative  to  all  Superfund
contracting  is  shown  in Exhibit  11.3-1.   As  the  table   shows,   minority
contracting accounted  for  6  percent of all Superfund contracting  on  a  dollar
value basis.   The  greatest  dollar value  of  minority firm work on  Superfund
projects was obtained through direct procurement by EPA.   The  types of services
that minority firms provided through direct procurement  can be  categorized into
three major areas:   professional, field  support,  and  construction.   Typical
services contracted or subcontracted to these firms  are listed below.

                                      124

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
Professional                     Field Support                 Construction

Health Assessment             Drilling/Well               Site  Cleanup
Community Relations            Installation              Excavations
Feasibility Studies           Laboratory Analysis         Waste Hauling
Data Management                                            Disposal
Geopbysical Surveys                                      Security
Remedial Investigations                                  Site  Support
Expert Witness                                             Facilities
Editing
Air Quality
Monitoring

     CERCLA cooperative agreements (CAs) are  contract-type arrangements between
EPA and  State  government agencies, local  governments,  and Indian Tribes  that
enable EPA to  involve  these non-Federal governments in  response activities  at
Superfund sites within their jurisdiction.  CAs specify work to be performed and
the funding allocated  for the work.  Governments  with CAs may establish  more
specific subagreements, some  of which involve minority  firms.  In FY87,  of the
$9,400,000 awarded to non-Federal  governments, $2,100,000  in  subagreements,  or
22 percent, were awarded  to minority  contractors.   These awards ranged  from a
low  of  $350  to  a  high  of $833,345.    The  services  rendered  under  the
subagreements  were primarily professional services  such as  architectural and
engineering work, and services related  to remedial design  for Superfund  sites.

     EPA interagency agreements  are similar  to cooperative agreements,  except
that the former are negotiated between EPA and other Federal  agencies, such  as
the Army Corps of Engineers.  These agencies  then allocate specific portions  of
their  interagency  agreements to  minority contractors  and other contractors.
Interagency transfers of Superfund monies during  FY87 amounted to $237,500,000.
Of this amount, $4,600,000 was placed with minority contractors.  The range  of
minority awards  was  from $4,755  to $4,200,000.    The  services  provided under
these awards  include conference support, automated data processing services, and
services related to  the study,  design, and  implementation of a site remedial
action.

     The total  $38,000,000  of Superfund program minority firm contracting  is
diagrammed in  Exhibit  11.3-1  by  type:   prime contracts; subcontracts; and SBA
8(a) contracts.  As  shown,  8(a)  contracts account  for the greatest amount  of
Superfund minority contracting, in terms of both the number of  contracts awarded
and the dollar value of the contracts.

     The data  for Exhibit  11.3-1  were  obtained  from a variety  of  sources.
Direct procurement figures were obtained from the Federal government's Contract
Information System  (CIS) .  The total  number of awards  and the  total dollars
awarded  through cooperative  agreements  were obtained through EPA's   Grants
Information Control System (GIGS).  The number of  minority subagreements awarded
and the  dollar value  of these  subagreements were  obtained by  EPA  Regional
offices from Standard Form 334.
                                      125

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                      Progress Toward Implementing Superfimd:  Fiscal Year 1987
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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     The total  number  and dollar value of  Interagency Agreements was  obtained
from the GIGS.   The minority contractors'  share  of these figures was  obtained
from the Federal agency making the award by the use of EPA Form 6005-3.   Of the
20 Federal  agencies contacted, only  two,  the Army  Corps  of Engineers and the
Department  of  Health  and  Human  Services,  reported  any use  of minority
contractors.
                                      127

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


12.0  THE NATIONAL RESPONSE TEAM AND REGIONAL RESPONSE TEAMS

     The National  Response  Team (NRT) and the  Regional Response Teams  (RRTs)
execute Federal responsibilities in the preparation for  and coordination of on-
scene  response  operations.    The NRT,  consisting of representatives  from  14
Federal agencies,  is  responsible  for- national  coordination and  planning  of
preparedness and response actions.  Representatives from the  same 14 agencies,
as well as  State  designees,  make  up each of  the 13 RRTs.   The RRTs  oversee
regional preparedness planning prior to response and assist in the coordination
and operations of  response.

     NRT and RRT Accomplishments in Fiscal Year 1987

     The  NRT promotes Federal  preparedness  through  training coordination,
technical  assistance,  information  exchange,   contingency  planning,   and  by
fostering cooperation  between the  public  and private sectors.  In particular,
the NRT has assisted EPA with  the  development of  the  NCP in accordance  with
Executive Order 12580.  The NRT helped draft Subpart B  of  the NCP and reviewed
and commented upon the entire document.  In another CERCLA-related area,  the NRT
provided the  means for the FY89 Interagency Budget Task  Force to distribute
CERCLA funds to Executive departments and agencies.  Also  during FY87,  the NRT
established a standing RRT for the Pacific Oceania area.

     Established by the NRT in FY87,  the following committees have carried out
elements of the NRT's mission:

     •    The Management  Committee developed the  FY88  NRT Workplan
          and  prepared   a  procedures  manual  to  streamline  NRT
          operations;

     •    The Preparedness Committee  assisted in the development and
          review of the Hazardous Materials Emergency Planning Guide
          (NRT-1);

     •    The Training Committee developed the NRT  training strategy;
          and

     •    The Computer Applications Committee began development of a
          directory  of  Federal  information  resources   and other
          computer-based tools to enhance preparedness for,  prevention
          of, and  response to chemical incidents.

     RRTs

     Regional Response Teams,  in accordance with their FY87  workplaris, conducted
a variety of preparedness activities, such as simulated response exercises and
training seminars.  The  RRTs  also developed RRT  FY88  preparedness workplans
tailored to Regional  needs.   When requested by Federal on-scene coordinators
during FY87 emergency responses, RRTs were activated to  provide  information and
technical services.
                                      128

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


13.0  EXECUTIVE BRANCH ESTIMATE OF RESOURCES NEEDED TO COMPLETE
      SUPERFUND IMPLEMENTATION

     13.1 Introduction

     CERCLA section 301(h)(l)(G) requires EPA to estimate  the resources needed
by  the  Federal  government to  complete  Superfund implementation.   The Agency
interprets  this  requirement   to   mean  the  cost   of  completing  CERCLA1s
implementation  through  the  current  authorization  (FY91)  and  beyond.    The
preliminary  estimate  included  in   this   chapter,   however,  only  includes
information up  through  1989.   Congress provided EPA with  $3,964,000,000  in
budget authority for  the implementation of CERCLA,  as  amended,  for the three
year period, fiscal 1987 through 1989.  The budget authority provided for each
respective fiscal year is:

               •    FY 1987 - $1,411,000,000
               •    FY 1988 - $1,128,000,000
               •    FY 1989 - $1,425,000,000

The actual  level of  funds obligated in each fiscal  year  may be slightly less
than the  level  of budget  authority provided.   Data on  the  resources needed
beyond 1989 are  in  the early  stages  of development, as part of the 1990 budget,
and thus cannot be included in this Report.

     The resources  estimate in this  chapter  is divided between resources needed
by EPA and those needed by other Federal departments  and agencies.   It is based
primarily upon the responsibilities and  duties assigned to  EPA and  other Federal
departments and  agencies by Executive  Order  12580,  some  general  assumptions
about the overall size and cost of the Superfund program, and data submitted  to
EPA  by  other   Federal   departments  and  agencies.    This estimate  includes
assumptions about the size and scope  of the Superfund program,  the nature and
number of  response actions,  participation by States and  private  parties,  the
increasing use of treatment  technologies,  and other factors.   In the case  of
EPA, these  assumptions  relate to  management of  the workload already  in  the
remedial pipeline.

     In developing the resource estimate required by section 301(h)(1)(G),  EPA
considered several  sources:

     •    EPA Superfund budgets for fiscal years 1987, 1988, and 1989,
          including budget requests from other Federal departments and
          agencies;

     •    Data that Federal departments  and  agencies  submitted to EPA
          under  an  approved General  Services Administration (GSA)
          interagency report  control number  (IRCN) issued on February
          5, 1988 as  required under the  provisions of 41 CFR 201-45.6
          (IRCN  0354  EPA -- Annual);

     •    The  Federal  Agency  Hazardous   Waste   Compliance  Docket
          developed under CERCLA section 120(c) and individual Federal
                                      129

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


          department or agency Annual  Reports  to Congress on Federal
          Facilities Implementation required under section 120(e)(5);

     •    EPA's Report to Congress under CERCLA section 301(a)(1)(C) ,
          which  is  entitled Extent of the Hazardous Release Problem
          and Future Funding Needs  (December 1984);

     •    EPA's Annual Report to  the Office of Management and Budget:
          (OMB) on Pollution Abatement  Needs at Federal Installations,
          which  is  submitted under  Executive Order  12088;  and

     •    Various  EPA  information  systems,  primarily  the  financial
          management system (FMS).

     Although these sources will be used for future Reports, the Agency also is
working  to   identify  data  requirements, improve  data  quality,  develop  cost
estimating methods, and  collect  additional information.   Specifically,  EPA is
working to prepare  a more complete estimate for the current authorization, in
the  out-years  of  1990  and  1991,  and  the  unfunded  period beyond 1991  by
conducting:

     An RI/FS Cost Study

     This detailed  and  comprehensive  study is  expected to  provide  information
on  completion   periods,   costs   associated  with  various   activities,   cost
relationships  between NPL EPA-lead  and State-lead  actions,  and   other  cost
components.  The  study was  completed  in  fiscal year 1988.

     An Analysis of Superfund's  Unfunded Liability

     This long-term effort will be coordinated with the development  of the 1990
budget.  In conjunction with the proposal of the NCP and its policies affecting
program direction and scope, EPA should be in a position by fiscal year 1989 to
project a more complete implementation cost estimate.

     EPA's  ability to  project  the Federal  resource  requirement   for  CERCLA
implementation will improve with the publication of the final NCP and more than
two  years of  experience  implementing  CERCLA,  as amended by  SARA.   Better
coordination with other Federal departments and agencies and additional data on
the  implementation of  the  Federal  Facilities  requirement of  section 120 will
also help to  improve the  estimate.

     132  EPA Estimate of Resources Necessary to  Complete Superfund Implementation

     In   estimating  the   resource  requirements   of  EPA  to   complete  the
implementation of CERCLA, the Agency  typically  focuses  its  projections  on the
costs of the remedial and removal programs in future years.  These two response
program areas are the major components of the Superfund program and  account for
the  large majority of the  Agency's  Superfund  expenditures.   The  estimates of
the resource needs  for  these two program areas are projected  for fiscal years
1988 and  1989.
                                      130

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


     Developing  a complete  and  accurate estimate  of  the  costs  to  EPA of
completing Superfund implementation is dependent upon a number of factors, many
of which could change  in  future  years.   Presently, the most  important  factors
are:

     •    Changes in Superfund program policies and procedures -due to
          the  revised  NCP,   particularly  the  cleanup   standards
          requirements of CERCLA section  121;

     •    Changes in the remedial program due to the  revisions to the
          HRS required by CERCLA section  105;

     •    Changes in the character and size of  the CERCLIS  inventory
          and, as a consequence,  the  facilities that  are added to the
          National Priorities List;

     •    The effects of  the  long  time period required to  identify,
          develop, select, and construct a remedy,  particularly  those
          using treatment technologies;

     •    The level of State Superfund program  activity;

     •    The level of potentially responsible party  participation in
          the program; and

     •    The nature of and demand for removal  actions.

     Superfund expenditures support  EPA activities in three major categories:
program support,  site-related support, and direct site support.   Over  time, the
distribution  of   resources  among  those  functions  will  vary  as  the  program
matures, and with changes in policy,  direction,  and the inventory and  character
of sites.   EPA's  Superfund budget also  supports  other Federal  department and
agency activities funded from the Hazardous Substance  Superfund.

     Program Support

     In FY87, this category accounted for approximately 12 percent of  Superfund
resources, and was used to support:

     •    Information management;
     •    Policy and planning;
     •    General administration;
     •    Training;
     •    Community assistance grants;
     •    Siting capacity grants;
     •    Office of the Inspector General; and
     •    Support for other Federal departments and agencies.

     Program support resources are used in four principal areas:  (1)  general
and financial administrative support  (24 percent);  (2)  research and support for
other Federal departments  and agencies (25 percent); (3) information management,
policy  and  planning  activities  (24  percent);  and  (4)  siting and   community


                                      131

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


assistance, EPA Office of the Inspector General support, and miscellaneous other
activities (27 percent).

     Site-Related Work

     In FY87, this category accounted for approximately  7 percent  of  Superfund
resources, and was used to support:

     •    National Response Team and Regional Response Team activities;
     •    Cost recovery action under CERCLA section 107;
     •    Health studies and research; and
     •    Criminal casework.

     Site-related work resources  are  largely  accounted for  by  NRT and  RRT
support (36 percent),  and preliminary enforcement and cost  recovery activities
(41 percent).  The remaining 23 percent supports research for program support,
criminal casework, and other miscellaneous activities.

     Direct Site Support

     In FY87, this category accounted for  approximately 81 percent  of  Superfund
resources, and was used to support activities in two areas:

     •    Direct Site Work

          Removal actions;
          Remedial actions;
          Pre-remedial/site assessments; and
          Engineering and design studies.

     •    Site Support

          Extended remedial actions;
          Community relations;
          Contract laboratory support;
          Contract management;
          Enforcement;
          Potentially responsible party settlements; and
          Superfund Innovative Technology Evaluation (SITE)  program.

     The  bulk of  these resources,  approximately 77  percent,   is; devoted  to
removal and remedial actions, including extended remedial actions.

     Any  improvements  which are made in  developing  a  preliminary estimate  of
EPA's Superfund  implementation  resource needs  will  depend,   to a large  degree,
on changes involving remedial program costs,  cost  recovery revenues, and direct
cleanup actions  taken by potentially responsible parties.

     Potentially responsible parties contribute to the hazardous waste  cleanup
effort by undertaking and financing voluntary or enforced remedial activities,
thereby reducing the  number of  remedial actions requiring  government funding.
                                      132

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


EPA is currently developing and implementing policies designed to encourage PRP
cleanups.

     132.1  Remedial Program Costs

     Remedial actions  are currently  the  single largest category  of  Superfund
expenditures and are expected  to  remain so  in the  future.   In order to project
EPA  funding needs  for  the  remedial  program,  several  key  factors  must  be
estimated:

     •    The projected size of the NPL;

     •    The  projected  number  of   RI/FSs,  remedial  designs,  and
          remedial actions undertaken;

     •    The average cost of  an  RI/FS, RD,  and RA;  and

     •    The direct cleanup actions  taken  by responsible parties.

     Exhibits  13.2-1  and  13.2-2  present  data  on  EPA  Superfund  resource
requirements  in workyears  and dollars,  respectively.   Summary  data on  the
principal elements of EPA's Superfund workload are presented in Exhibit 13.2-3.
Exhibit 13.2-4  presents an estimate  of the EPA Superfund  interagency funding
requirements, by fiscal year.


                                   Exhibit 13.2-1
                     EPA Superfund Staffing Requirements
                                 by Fiscal Year
                          (full-time equivalent workyears)
Program Area1
Hazardous Substance
Research
Response
Enforcement
Management and
Support
Total
'See section 5.4 for more information
1987
Actual

93,4
963.4
764.5
353.0
2,174.3
on the content of
1988
Current
Estimate

85.6
1,100.1
965.9
481.4
2,633.0
these EPA program areas.
1989
Budget
Request

102.8
1,240.9
917.5
488.8
2,750.0

                                      133

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                    Progress Toward Implementing Superfund:  Fiscal Year 1987
                                          Exhibit 13.2-2
                                 EPA Superfund  Funding
                              Requirements by  Fiscal Year
                                   (dollars in thousands)
Program Area
                      1988            1989
      1987        Operating         Budget         1987-1989
     Actual          Plan           Request          Total
Program  Support
  $126,089.9      $194,840.8      $247,340.9      $568,271.6
Site Related Work
    73,552.4
111,761.7
 92,389.3
 277,703.4
Direct Site Work/
  Support
   851,106.6     1,292,897.3      1,085,269.8      3,229,273.7
  Site Work
   655,352.1
951,349.1
695,653.4     2,302,354.6
    Removal Actions
    Pre-Remedial Work
    Engineering & Design
       Studies
    Remedial Actions1
    Other
    122,061.0
    36,341.0
   205,344.1


   205,398.3
    86,207.7
121,742.0
 60,115.0
217,594.0


514,205.6
 37,692.5
124,792.0
 58,043.0
171,350.0


298,253.0
 43,215.4
 368,595.0
  154,499.0
 594,288.1


1,017,856.9
  167,115.6
  Site Support

Total Superfund2
   195,754.5
341,548.2
389,616.4
 926,919.1
$1,050,748.9    $1,599,499.8    $1,425,000.02   $4,075,248.7
1The FY 1989 budget request assumed $100,000,000 carryover funding to be used for RAs, bringing the total request to
$1,525,000,000 and remedial action figures to $398,253,000.

'Includes funds transferred to other Federal departments and agendas from the Hazardous Substance Superfund appropriation (Trust
Fund) via (1) the Superfund Interagency Budget (see Exhibit 13.2-4), and (2) site-specific interagency agreements (lAGs). The costs
shown here for remedial activities include first starts, subsequent starts, and work-in-progress. In setting mandatory schedules, e.g ,
that for remedial actions, Congress focused on first starts only (see CERCLA section 116(e)). On average, program support activities
are 14% of resources, site related activities are 7%, and site work and support activities account for the balance of 79%.
                                               134

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         Progress Toward Implementing Superfund:  Fiscal Year 1987
                                Exhibit 13.2-3
Summary  Of EPA Superfund  Workload  by Fiscal  Year1
                                                    1988           1989
Activity2                          1987          Estimate      Estimate
Removal Actions                   304              190               190
Pre-Remedial  Actions

    PA Completions3             4,001            2,432             2,500

    SI Completions               1,343            1,223             1,325

    NPL Sites4                      64              296               125
Remedial Sites9
RI/FS Starts*
RD Starts
RA
Starts
Final/Completions7

123
76

41
8

105
134

68
8

115
106

76
22
'The workload data shown are for Trust Fund-financed actions and those undertaken by potentially
responsible parties at NPL faalities/sites only. The numbers shown are by year and are not cumulative.

The Agency expects to  meet, or has met, the goals and mandatory schedules set out in CERCLA
sections 105, 116, and 120, except for site inspections (Sis).

'EPA met the statutory goal for preliminary assessment (PA) completions during fiscal year 1987.  to
complete a PA for each site in the CERCLIS inventory without a PA by January 1988.

'Facilities/sites proposed  for final listing on the NPL.

"Data are for first starts only; subsequent starts are not included, although they account for a significant
part of the workload.

"EPA also expects to satisfy the statutory RI/FS schedule: to start 275 RL/FSs by October 17, 1989.

'Data are for completion of all construction work at sites.
                                      135

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         Progress Toward  Implementing Superfund:  Fiscal Year 1987
                                 Exhibit 13.2-4
              EPA Superfund Interagency Funding
                              by Fiscal  Year1
                          (dollars  in thousands)
Federal
Department
or Agency
Health and
Human Services
ATSDR
NIEHS2
Justice
Transportation
USCG
Commerce
NOAA
1987
Actual
$32,439.3
32,439.3
10,918.6
4,023.3
1,819.9
1988
Operating
Plan
$71,915.0
43,000.0
28,915.0
16,373.0
4,948.2
2,280.1
1989
Budget
Request
$58,915.0
43,000.0
15,915.0
16,700.0
4,948.2
2,280.1
Federal Emergency
  Management Agency  1,173.7
Interior

Labor
    OSHA

Interagency
  Subtotal
     687.0
     281.3
$51,343.1
   1,969.6

   1,253.6


   1.008.2
1.879.6

1,253.5


1.008.2
$99,747.7        $86,984.6
Trust  Fund Total3  $1,050,748.9       $1,599,499.8     $1,425,000.0"
'The resources shown here are those transferred to other Federal departments and agencies via the
EPA Superfund Interagency Budget only.  In addition to these resources, in fiscal 1987 only.
approximately $14,804,900 was also transferred  to  other Federal departments and agencies via site-
specific interagency agreements (lAGs)  for support to EPA at Superfund sites. These two sources
provided a total of approximately $66,148,000 or 6 percent of the total obligated Trust Fund amount
of $1,050,749,000.

All funding for SARA Title III activities came  from the Hazardous Substance Trust Fund and is
included in the $14,804,900 EPA obligated for site-specific lAGs.  Resources  transferred from the
Hazardous Substance Superfund to other Federal departments and agencies  are presented solely in
dollars and not workyears, although some of these funds may be used to develop personnel
positions for  CERCLA activities and support.

'NIEHS obligated $13,000,000 in fiscal 1987 against its reimbursable authority but did not report its
obligations to EPA until 1988.  EPA obligated $13,000,000 m fiscal 1988 to reimburse NIEHS for its
fiscal 1987 costs.

Trust Fund total includes Superfund interagency funding.

"FY 1989 total does not include anticipated $100,000,000 carryover from previous year nor does it
reflect Congressional reduction in budget requests.
                                        136

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                 Progress Toward Implementing Superftind: Fiscal Year 1987


           Cost Recovery Revenues

     In addition to the direct remedial and removal actions that are undertaken
by PRPs,  a portion of  the costs  of  certain Fund-financed response actions will
be  recovered  from  PRPs through enforcement  activities.    The  cost  recovery
revenues obtained from PRPs  will  ultimately reduce  the overall costs of both the
remedial and removal programs.  In general, it takes about three years from the
time EPA makes an expenditure from the  Trust  Fund for final site work  to the
time these response costs are reimbursed to EPA by PRPs.

     The cost  recovery  rate for  remedial expenditures  is subject to a range of
possible estimates  given varying  assumptions  about:   (1)  the  probability of
successful  litigation;  (2)  the   ability  to  recover  interest  costs  from
litigation; (3) how many NPL sites will be  cleaned up by private parties without
the use of the Fund;  and (4) the  role  of new CERCLA settlement provisions, such
as mixed  funding and  de minimis  settlements.   To date,   Fund-financed  remedial
action generally has been taken  at  sites where PRPs are potentially capable of
taking on  cleanup  responsibility.   The  cost  recovery  rate for  these  sites is
likely to be relatively high.

     In  future  years,  as  the  rate   of  successful  EPA  enforcement  actions
increases, more PRPs are expected to undertake actual cleanups  directly.  As a
result, more Fund-financed  actions  may be  taken at sites where  there are fewer
financially-viable PRPs connected  with  the sites.   The  probability of cost
recovery for these sites may be  lower  than for previous sites.

     While the cost recovery revenues obtained from PRPs will  reduce the costs
of the two response programs to  EPA, the available data for  these revenues are
not sufficient to allow for  an  accurate  estimate  of  the percentage  of Fund-
financed remedial  and  removal costs  that  will be recovered  from PRPs.   The
Agency  is  putting  significant  effort  into  improving  its   cost  recovery
performance.   The fiscal  1987  cost  recovery  amount  was the  highest  in the
program's history.

     133   Other Executive Branch Department and Agency Estimates of Resources Necessary to Complete
          Superfund Implementation

     The   second  element   in  fulfilling  the  CERCLA   section  301(h)(l)(G)
requirement for this Report  is to estimate  the resources needed by other Federal
departments and agencies.   EPA requested  the  resource  requirement  information
from  the  other  Federal  departments  and  agencies under  an  approved  GSA
interagency report control number issued on February 5,  1988,  as required under
the provisions of 41  CFR  201-45.6.   Although EPA received fairly  detailed
information for fiscal  1987,  EPA anticipates collection of more comprehensive
information for the fiscal  1988 Report.

     The  resource needs of  the other Executive  branch departments and  agencies
for Superfund  implementation activities  are met through two  sources:

     •    Hazardous Substance Superfund  (Trust  Fund)
                                      137

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


          Interagency Budget:     These  funds  are  transferred  to  other
          departments and agencies  by EPA from the Hazardous Substance
          Superfund  through an  interagency budget  under  Executive
          Order 12580.

          Site-Specific Agreements:   These  funds  are  transferred to  other
          departments  and  agencies  from  the   Hazardous  Substance
          Superfund by EPA  through site-specific agreements.

     •    Individual Federal Department  or  Agency Budgets

          CERCLA-Specific Funds:    These  funds  are  budgeted  by  the
          individual departments or  agencies specifically for CERCLA
          activities and  support  as  part  of the  President's  annual
          budget submission.

          General Funds:  These funds are utilized for CERCLA activities
          and  support  by  other   departments  or  agencies  and  are
          obtained from  general budget  resources  or are taken from
          resources designated for other programs.

     The reported resource  needs of  other Federal  departments and agencies are
summarized in Exhibit 13.3-1.  Exhibits  13.3-2 and 13.3-3 present estimates of
CERCLA implementation  resource  requirements from  other Federal department and
agency budgets in dollars and workyears,  respectively.  Information provided by
other departments and agencies to  supplement those numbers  is included below.

     Department of Defense

     Since  1984,  there has been  an increased  emphasis  on  this  Department's
efforts to clean up contamination  from hazardous waste  sites  under the Defense
Environmental Restoration Program.   As  a  sub-element of the Defense  Environ-
mental Restoration Program, the Installation Restoration Program's objective is
the  cleanup of contamination  from  past  activities  in accordance with  the
procedures and  requirements of  the NCP.   The preliminary studies  and  remedial
investigations  that have  been performed for sites in the past  few years under
this program are now leading to the  identification of needed  response  work.

     The Department  of Defense  estimates  the total  cost of the  Installation
Restoration Program work to be between $11,000,000,000 and $14,000,000,000. The
uncertainty in  the  total funding  requirement  for this program exists because
there are still  many  remedial investigations to be completed and many agreements
have not yet been signed with EPA  and State agencies.

     Department of the Interior

     The Fund appropriation under  general lAGs  for DOI activities will enable
the nine DOI bureaus  to  participate more effectively on  the  National  Response
Team and will be used for development of State and local  contingency plans and
development of  procedures for natural resource damage assessments.
                                      138

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                   Progress Toward Implementing Superfund:  Fiscal Year 1987
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                                            139

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        Progress Toward Implementing Superfund:  Fiscal Year 1987
                               Exhibit 13.3-2
               Federal Superfund Implementation
            Funding Requirements  by Fiscal  Year
                        (dollars in thousands)

Federal Department
or Agency1

1987
Actual

1988
Planned
1989
Budget
Request
Defense2                    $375,900        $402,800     $436,100

Interior                         6,900            9,600       24,700

Energy                        38,963          180,506      128,802

Transportation                 6,615            7,803         8,639

General Services                150              261         1,575
     Administration

National Air and                   --            23,900       26,000
     Space Administration3

Tennessee Valley                200
     Authority

Veterans                           --                 --          5,000
     Administration

Commerce                       557              587           616

Federal Emergency            1,522
     Management Agency
'Data shown for departments and agencies are for funds budgeted independently by these
departments and agencies, and exclude resources from the Hazardous Substance Superfund.  Also
see Exhibit 13.2-4 for specific information on resources received by these departments and agencies
from the Hazardous Substance  Superfund via the EPA Superfund budget/appropriation.  Data were
not available from the Departments of Labor, Justice, and Health and Human Services.

The numbers provided  by the Department of Defense are for its Environmental Restoration
Program. Only a portion of this program, the Installation Restoration Program, is directed towards
Superfund-type cleanup, the total cost of which is expected to be in the range of $11-
14,000,000,000.

'Estimate of resources needed to fully implement NASA's environmental compliance and restoration
program. A portion of the facilities being addressed by this program are Superfund cleanup sites,
but NASA data do not distinguish these resources.
                                     140

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                  Progress Toward Implementing Superfund:  Fiscal Year 1987
                                     Exhibit 13.3-3
                         Federal Superfund  Implementation
                       Staffing  Requirements by Fiscal  Year
                           (full-time equivalent workyears)
Federal Department
or Agency
Interior
Transportation
General Services Administration
Commerce
Federal Emergency
Management Agency
1987
Actual
71.0
168.5
0.3
14.4
40.0
Note: Data were not available from the Departments of Defense,
and Human services, NASA, TVA, and VA.
1988
Planned
79.0
171.5
4.0
19.7
52.0
Labor, Energy,
1989
Budget
Request
101.0
173.5
19.0
21.6
61.0
Justice, Health
     Department of Transportation

     The  Fund  appropriation through  general  lAGs will  enable  the USCG  to
maintain its response capabilities, ensure that CERCLA financial responsibility
requirements are met, train  emergency  response personnel using program modules
and  simulation drills,   staff  the CERCLA  component of  the NRC,  and maintain
chemical  information  systems  and  records  of  characteristics  for  certain
chemicals.

     The Department  of  Transportation estimates that  it will  use  1988 funding
from its department  budget  for  the USCG and the Research  and  Special Programs
Administration  to  completely fulfill  their  Superfund responsibilities.   This
will  include   Superfund cleanup  projects  at  USCG   and Federal  Aviation
Administration  (FAA)  facilities  as well as third  party liability  costs  as  a
result  of  the  involvement   of  the Maritime Administration as  a  de  minimis
potentially responsible party at a nuclear waste site in Maxey Flats, Kentucky.
In addition,  DOT projects that it  will  require funding for third party liability
costs   from    1989,   and  perhaps  beyond,   resulting   from  the   Maritime
Administration's involvement at the Maxey  Flats site.
                                      141

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     General Services Administration

     Within the  1988 budget  request  estimate,  GSA proposed allocating $100,000
for  one  Superfund project at  its facilities.   In addition, GSA  is currently
involved  in  five Superfund  site  investigations  in  which it is  a PRP.   As a
result, GSA estimates that it will incur third-party PRP costs in future years.

     Department of Commerce

     General IAG monies  will allow NOAA to provide  and  evaluate  updated field
monitoring methods  for  sampling  and analyzing  contaminants discharged into
marine environments; develop computerized contingency plans for selected ports;
provide  updated  protective  equipment;  and participate  on  Regional  Response
Teams.  The resource estimates  do  not include resources necessary to meet NOAA's
role as a Federal trustee for  natural resources.

     Department of Justice

     The  FY88  resources for  the Department  of  Justice  under  general  lAGs
represent  an  increase from  1987  for an expanded Superfund caseload  and the
operation of a system that provides  automated  data support  for  complex cases.

     Department of Labor

     Funds appropriated under general  lAGs  will allow OSHA  to continue  to
provide EPA and other response  personnel with technical assistance in protecting
workers at Superfund sites,  implementing the worker safety program at Superfund
sites, and supporting the National and Regional  Response Teams.

     Federal Emergency Management Agency

     Funds appropriated  under  general lAGs for FEMA's ongoing  activities will
enhance  State,  local, and  Federal  emergency  preparedness  and  administrative
support.  These  funds will be  used for FEMA's  support  of the Regional Response
Teams  and will  provide management  support and oversight  for temporary and
permanent relocations.  Funding for temporary or permanent relocation activities
will  be  provided   from  resources  under  EPA's  Hazardous  Substance  Response
program.
                                       142

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


14.0  OTHER EPA ACTIONS TO IMPLEMENT CERCLA

     EPA undertook several  actions to implement provisions added  to  CERCLA by
SARA to address particular  issues.

     14.1 Implementation of CERCLA on Indian Lands

     Section  207(e)  of SARA amended CERCLA to add a new section 126  on Indian
Tribes.  In accordance with the mandate that EPA treat Indian Tribes as States,
the Agency  is planning to award cooperative agreements to Tribes  so  that  they
may conduct response actions.   EPA is developing an  administrative regulation
that will establish the requirements Indian Tribes must satisfy in conducting
response actions with EPA funds.

     Study of Hazardous Waste Sites on Indian Lands

     Section  126(c) requires the President to "conduct a survey,  in  consultation
with the  Indian Tribes,  to  determine the extent of  hazardous  waste  sites  on
Indian lands.   Such survey  shall be included within a report which shall  make
recommendations on the  program needs  of  Tribes under  this Act,  with particular
emphasis on how Tribal participation in the administration of such  programs can
be  maximized.   Such  report  shall be  submitted to  Congress  along with  the
President's budget request for fiscal year 1988."  EPA submitted this Report to
Congress on November  6,  1987.

     The Report is based largely on data from an EPA-funded  survey  completed in
July 1985 by  the Council  of  Energy  Resource  Tribes  (CERT) in  consultation  with
Indian Tribes.   The  CERT survey was  limited in scope and  extended only  to  a
sample of Indian lands.  Because  of  the brief time between the enactment of  SARA
in October  1986  and the date in  early  1987  by  which submittal of  this  Report
was required,  EPA did not feel it was possible to conduct a comprehensive survey
of hazardous  waste  sites  on  Indian  lands.

     The Report:   (1) provides background on the  Superfund program  and explains
the special status accorded  Indian lands under the Federal system;  (2)  describes
the approach  and  data sources used for the report;  (3) presents findings  from
these data sources on the extent  of the hazardous waste site  problem  on Indian
lands;  and  (4) presents recommendations on program needs of Indian Tribes  and
the Agency's  commitments  to address  those needs.   A  brief  summary of  the
Report's findings  and recommendations follows.

     An EPA-funded survey that  CERT  completed  in  1985,  in consultation  with
Indian Tribes, included 1,196 reports of potential hazardous waste  generators
and sites on  or near 25 selected Indian reservations.  This  sample  represents
about 10 percent of the 278 Federal  Indian reservations.   Data from  supplemental
sources, including  discussions with Tribal representatives  and the Department
of the Interior's  Bureau of Indian Affairs, confirm  that there are  potential
hazardous waste sites on  Indian  lands in need of investigation.

     Analysis of the data suggests,  however,  that the  number of  potential sites
requiring investigation on the 25 reservations is significantly lower  than the
1,196 reports in the  CERT survey.   Over half of the reports  (645)   are  derived
                                      143

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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


from an EPA data base of active hazardous waste generators and waste management
facilities.  In addition, sites near but not on reservation land were included
in the  survey.    EPA's  inventory of  potential hazardous  waste  sites due  for
assessment  under the  Superfund program already  includes  many  (467)  of  the
reports in the CERT data base.

     Based on these findings,  the following recommendations were offered:

     •    EPA will conduct preliminary assessments and,  if necessary,
          site  inspections   of potential  hazardous waste  sites  on
          Indian lands using the Agency's Superfund program resources,
          unless  a  Tribe   is  willing   and   able   to   conduct   the
          assessments;

     •    EPA will rely on its  own response infrastructure to plan and
          conduct response  actions  wherever needed  on  Indian lands;
          and

     •    Through education  and outreach programs,  EPA  will heighten
          Tribal understanding and  awareness of hazardous waste  site
          problems and provide information on Tribal participation in
          the Superfund program.

     142 Love Canal: Habitability and Land Use Study

     Section 312(e) of CERCLA requires the Administrator to conduct a study to:

     •    Assess the risks associated with inhabiting  the Love Canal
          Emergency Declaration Area  (EDA);

     •    Compare the  level  of hazardous waste contamination in the
          EDA to that present  in other comparable  communities; and

     •    Assess  the potential  uses  of  the  land  within the  EDA,
          including  but  not  limited  to  residential,  industrial,
          commercial, and recreational uses, and the risks associated
          with such potential  uses.

     As early as November 1983,  the New York State  Department of Health  (DOH)
and  the  U.S. Department of  Health and  Human Services,  Centers  for  Disease
Control (CDC),  as  members of  the Love  Canal  Technical Review Committee,  were
asked to  develop habitability criteria  applicable  to  the  EDA.   To  assist in
developing  such  criteria, DOH and CDC sought the opinions  and recommendations
of 10 distinguished scientists representing a  variety  of disciplines.

     After evaluating several  approaches to determine  habitability of the  EDA,
the scientific advisors recommended using a combination of relevant Federal and
New York standards, criteria,  or guidelines, and comparing levels of Love  Canal
indicator chemicals from  EDA neighborhoods with levels  of these  chemicals  from
similar neighborhoods that are not near a chemical landfill.   The  views  and
opinions of these advisors were considered in a document prepared by CDC and DOH
entitled Proposed Habitability Criteria for the Love  Canal Emergency Declaration Area.


                                      144

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                 Progress Toward Implementing Superfund: Fiscal Year 1987
     A comprehensive sampling program is the next step that will be carried out
as part of the full-scale habitability and land use  study;  the results will help
determine  the habitability  of  the  EDA.   In  addition,  the  results  will  be
provided  to  and discussed with  individual homeowners  as soon as  they become
available; and further investigation will  be  undertaken, if necessary.
                                      145

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             Progress Toward Implementing Superfund: Fiscal Year 1987
EPA Headquarters and Regional Superfund Offices
      Headquarters
      Environmental Protection Agency
      Office of Solid Waste and Emergency Response
      401 M Street, S.W.
      Washington, DC 20460
      (202) 382-461 0
      Region 1
      Environmental Protection Agency
      John F, Kennedy Federal Building
      Room 2203
      Boston, MA 02203
      (617) 565-371 5

      Region 2
      Environmental Protection Agency
      26 Federal Plaza
      New York, NY 10278
      (212) 264-2525

      Region 3
      Environmental Protection Agency
      841 Chestnut Street
      Philadelphia, PA 19107
      (215) 597-9800
     Region 4
     Environmental Protection Agency
     345 Courtland Street, N.E.
     Atlanta, GA  30365
     (404) 347-4727

     Region 5
     Environmental Protection Agency
     230 South Dearborn Street
     Chicago,  IL 60604
     (312) 353-2000
Region 6
Environmental Protection Agency
1445 Ross Avenue
12th Floor, Suite 1200
Dallas, TX 75270
(214)  655-6444

Region 7
Environmental Protection Agency
726 Minnesota Avenue
Kansas City, KS 66101
(913)  236-2800

Region 8
Environmental Protection Agency
999 18th Street
Suite 500
Denver, CO 80202-2405
(303)  293-1 603

Region 9
Environmental Protection Agency
21 5 Fremont Street
San Francisco, CA 94105
(415)  974-8071

Region 1 0
Environmental Protection Agency
1200 Sixth Avenue
Seattle,  WA 98101
(206)  442-5810
                                     146

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


                                  APPENDIX A

                     STATUTORY LANGUAGE FOR THIS REPORT
                                     AND
                  EPA AND EXECUTIVE BRANCH IMPLEMENTATION
                         OF CERCLA AS AMENDED BY SARA


CERCLA Section 301(h)  REPORT AND OVERSIGHT REQUIREMENTS.

     (1)  ANNUAL REPORT BY EPA.   On January 1  of  each year the Administrator of
the Environmental Protection  Agency shall submit an annual  report to Congress
of such Agency  on the progress  achieved in  implementing this Act  during the
preceding fiscal year.  In  addition, such report shall  specifically include each
of the following:

     (A)  A detailed description of each feasibility study carried out  at a
facility under title I of  this Act.

     (B)  The status and estimated date of completion of each such study.

     (C)  Notice of each such study which will not meet a previously published
schedule for completion and the new estimated date for completion.

     (D)  An evaluation  of newly developed feasible  and achievable permanent
treatment technologies.

     (E)  Progress made in reducing the number of facilities subject to review
under section 121(c).

     (F)  A  report  on  the status  of  all  remedial  and enforcement  actions
undertaken during the prior fiscal year,  including a comparison to remedial and
enforcement actions undertaken in prior fiscal years.

     (G)  An estimate of the amount of resources, including the number of work
years or personnel,  which would be necessary for each  department,  agency,  or
instrumentality which is  carrying out any activities of this  Act to complete the
implementation of all duties vested in the department, agency, or instrumentality
under this Act.

     (2)  REVIEW BY INSPECTOR GENERAL.   Consistent with the authorities of the
Inspector  General Act  of  1978  the Inspector  General  of  the  Environmental
Protection Agency shall review any report submitted under paragraph (1) related
to EPA's activities for reasonableness  and accuracy and submit to Congress,  as
a part of such report a report on the results of such review.

     (3)  CONGRESSIONAL OVERSIGHT.  After receiving the reports under paragraphs
(1) and (2)  of this subsection in any calendar  year, the appropriate authorizing
committees of Congress  shall conduct oversight hearings to ensure that this Act
is being implemented according  to the  -purposes of  this  Act and  congressional
intent in enacting this Act.
                                      147

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


CERCLA Section 105  NATIONAL CONTINGENCY PLAN

     (f)  Minority Contractors.   In  awarding contracts  under this  Act,  the
President shall  consider  the availability  of qualified minority  firms.   The
President shall describe,  as part of any annual report submitted to  the Congress
under this Act,  the  participation of minority firms  in contracts  carried out
under this Act.  Such report  shall contain a brief description  of the contracts
which have been awarded to minority firms under this  Act  and  of  the  efforts made
by the President  to encourage the participation of such firms  in  programs carried
out under this Act.

CERCLA Section 121(c)  REVIEW

     If the President  selects a remedial action  that results in any hazardous
substances,  pollutants, or  contaminants  remaining at the site,  the President
shall review  such  remedial  action no less  often than each  5  years after the
initiation  of  such  remedial  action  to  assure  that  human  health and  the
environment are being  protected by the remedial  action  being implemented.   In
addition, if upon  such review it  is  the judgment of the President that action
is appropriate at such  site in accordance with section 104 or 106, the President
shall take or require such action.  The President shall report to  the Congress
a list of facilities  for which such review is  required,  the  results of all such
reviews, and any actions taken as a result of such reviews.

                   EPA AND EXECUTIVE BRANCH IMPLEMENTATION
                        OF CERCLA AS AMENDED BY SARA

     The Superfund Amendments and Reauthorization Act of 1986 (SARA) was passed
by  the  Senate  and  House  of  Representatives  on   October  3 and 8,  1986,
respectively, and signed by the President on October 17, 1986.

     Section 115 of CERCLA authorizes  the President  to delegate authorities for
executing the Act.  In response to the SARA amendments to CERCLA, the President
issued Executive Order 12580 on  January 23,  1987,  delegating authorities and
assigning  duties  to  various executive  departments  and agencies.   Primary
authority and responsibility  for carrying out the  Superfund program  was assigned
to the Administrator of EPA.

     Other organizations, departments, and agencies received specific authorities
in the Order,  e.g.,  the National  Response Team (NRT) plays  a role in revision
of  the  National  Contingency Plan  (NCP)  and  other specified  regulatory  and
response activities;  the Coast Guard  generally oversees  response in the coastal
zone, Great Lakes, ports  and harbors; and the Agency for Toxic Substances and
Disease Registry (ATSDR) performs  various health assessment functions. Executive
Order  12580  also  revoked  the previous Order,  No.   12316  of  1981,  which had
delegated  authorities vested in  the  President by the   original  Superfund
legislation of 1980.
                                      148

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                 Progress Toward Implementing Superfund: Fiscal Year 1987


     EPA Organization and Operations for CERCLA Implementation

     The Administrator  signed final internal  EPA delegations of  authority on
December 11, 1986, and  on August  14, and September  13  and 21,  1987.

     Following delegation from the President,  the EPA  Administrator  may retain
all authorities assigned to  him; ordinarily, however, he delegates many specific
Superfund  authorities  and  responsibilities  to  the  program  offices of  EPA.
Generally, the Administrator delegates authority to senior management officials
that report directly to  the Administrator.

     The Administrator  assigns most  responsibilities for  carrying out specific
CERCLA  provisions  to   EPA Regional  Administrators   and  to  the   Assistant
Administrator for  the Office of Solid Waste and Emergency Response (OSWER).  A
wide variety  of other  EPA  offices  also  play  roles in CERCLA implementation.
These other offices include the Office of Enforcement and  Compliance  Monitoring
(OECM),  the Office of Research and  Development  (ORD),  and the Office of Solid
Waste (OSW).  Each internal delegation indicates whether or not  the authority
for  executing a  Superfund provision  may  be  redelegated.    If  authority  is
redelegated, the original delegatee remains accountable to the Administrator for
exercising the authority.

     Two program  offices work within OSWER to  administer  the  major  activities
of CERCLA.  OWPE executes the enforcement-related activities of Superfund through
its  CERCLA Enforcement  Division.   OERR  is responsible for administering the
Superfund response program.

     EPA Interagency Agreements and Memoranda of Understanding with Other Federal Agencies

     In coordinating CERCLA's  implementation,  EPA occasionally exchanges goods
and  services  with other Federal  agencies  and with State  governments.   Such
exchanges are governed by interagency agreements (LAGs).*  The IAG is a written
agreement designed to carry out  a distinct project whose  objective  is clearly
defined.  All activities under an IAG must serve the objective through the term
of the project.  EPA undertook an initiative  to promote consistent use of lAGs
and  to  improve  accounting  and  cost  documentation practices.   A  draft  manual
entitled Regional Processing of Superfund lAGs was  distributed in July 1987.

     EPA  lAGs  may be  divided  into  two  major  classes.   The  first  class  is
characterized by  an exchange  of  goods  or services for monetary  reimbursement,
or a sharing  of  goods and  services between two parties.   The second class is
characterized by a policy agreement or Memorandum of Understanding (MOU).   The
MOU sets forth  the policies and  procedures governing  the relationship  of two
parties, or it governs the provision of services without monetary  reimbursement.
No funds are exchanged under an MOU.
     *Agreements between  EPA and States governed by a Superfund Memorandum of
Agreement   focus   on  environmental  problems,   objectives,   and  points   of
coordination.  Such agreements are not  considered lAGs.
                                      149

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                 Progress Toward Implementing Superfuud: Fiscal Year 1987


                                  APPENDIX B

                          FISCAL 1987 REMOVAL ACTIONS
     Removal actions vary greatly  in  length and are undertaken on a continuous
basis throughout the year.  Consequently, the table shows many FY87 starts that
will be completed in future fiscal years.   In addition, some completions noted
are for starts  in prior fiscal years.  Start dates  signify the first day that
the ERCs contractor is  onsite.  The completion date  marks  the day  that  all waste
is at  its  ultimate disposal  location.   See  section  2.2  of  this  Report for  a
summary of removal actions by State and Region.
                                      150

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                                                                         160
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


                                  APPENDIX C

                          DETAILED ROD DESCRIPTIONS


     This appendix provides  detailed  descriptions of FY87 feasibility  studies
(FSs) as required by CERCLA section 301(h)(1)(A).   These descriptions  are based
on Records of Decision (RODs) signed after 11/17/86, when the section 121  cleanup
standards added by SARA became fully effective. Although a total of 75  RODs were
signed in FY87,  four of these were signed before 11/17/86; 70 RODs are summarized
in  this  appendix (rather  than 71) because  a single  ROD was  signed for  two
actions:  the Environ-Chem and Northside Landfill  sites  in Indiana.

     Each  summary provides  background information  on  the  Superfund site,
including the type of operation, contaminants of concern, past  investigations,
description of operable units,  and the enforcement status.  The  section  on site
work provides  the date  of the remedial investigation  (RI)  initiation and  key
findings  of the  RI.     The  third  section describes   the  FS,  including   the
alternative remedial actions considered, the major Federal or State applicable
or relevant and appropriate  requirements  (ARARs)  identified for the  site,  and
a summary of community involvement.   In the last section,  the selected remedial
alternative is described.  This section also provides  information on the use of
alternative or resource recovery treatment technologies  and how well the selected
remedy meets the requirements of CERCLA.

     All sites summarized in the appendix are listed below by EPA Region.   The
National Priorities List (NPL) number given is the site  ranking  as  of July  30,
1987.  Proposed NPL sites are placed in groups (Gr) corresponding to  groups of
50 on the final NPL.  Federal facility sites are placed in similar groupings  and
designated by the letter "F"  following the group number.  The  entity  leading  the
project is also listed,  i.e., Federal lead by the  EPA remedial program  and Fund-
financed (F);  EPA enforcement program  lead  (ENF); potentially responsible party
lead (PRP).
                                      161
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Progress Toward Implementing Superfund: Fiscal Year 1987
                   APPENDIX C

           DETAILED ROD DESCRIPTIONS.
                     (continued)

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
Site
Davis Liquid
Ottati & Goss/GLCC
Resolve Inc.*
Browning- Ferris South Brunswick LF
Chemical Control Corp.*
Cooper Road Dump
Diamond Alkali
Montgomery Twp . Housing Development
Renora Inc .
Waldick Aerospace Devices
Williams Property
Endicott Village Well Field
G.E. Moreau
Haviland Complex
Katonah Municipal Well
Suffern Well Field
Volney Landfill
Vega Alta Public Supply Wells
Kane and Lombard
Palmerton Zinc
Presque Isle
Saltville Waste Disposal
West VA Ordnance Works
Gold Coast Oil Corp.
NW 58th Street Landfill
Parramore Surplus Co .
Tri-City Conservationist Corp.
Tower Chemical Company
Powersville Landfill
Newport Dump
Sodyeco
Geiger
Independent Nail Co.
Palmetto Wood Preserving
Johns -Manville
Enviro-Chem Corp ./Norths ide LF**
Marion/Bragg LF
Seymour Recycling Corp.*
Liquid Disposal Inc.
Rose Township Dump
FMC Corp.
New Brighton (St. Anthony)*
State
RI
NH
MA
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
NY
NY
NY
PR
MD
PA
PA
VA
WV
FL
FL
FL
FL
FL
GA
KY
NC
sc
sc
sc
IL
IN
IN
IN
MI
MI
MN
MN
Region
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
NPL
Rank Lead
216
130
206
125
223
473
523
438
378
271
377
507
52
607
527
506
627
334
724
306
376
737
89
67
181
455
408
286
517
453
151
640
62
420
428
240/249
530
57
24
166
17
39
F
F
F
ENF
F
F
PRP
F
ENF
F
F
F
ENF
F
F
F
F
ENF
F
F
PRP
F
PRP
F
F
F
F
F
ENF
F
PRP
F
F
F
PRP
ENF
F
ENF
F
F
PRP
F
Page
193
196
198
201
204
207
209
211
214
217
220
223
225
228
231
234
237
240
243
246
248
250
252
254
257
260
262
264
267
270
272
274
276
279
282
285
288
291
294
297
300
303
                        162
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                  Progress Toward Implementing Superfund: Fiscal Year 1987
                                    APPENDIX C

                            DETAILED ROD DESCRIPTIONS
                                      (continued)

43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
Site
New Brighton (TCAAP)*
Industrial Excess LF
Laskin/Poplar Oil*
Northern Engraving Corp .
Schmalz Dump*
Bayou Bonfouca*
Cleve Reber
Compass Industries LF
Sand Springs Petrochemical
Crystal City Airport
Highlands Acid Pit*
Petro- Chemical Systems, Inc.
Conservation Chemical Co.
Minker (Romaine Creek)*
Minker (Stout)*
Clear Creek/Central City
Denver Radium (I)*
Denver Radium (II)*
Denver Radium (III)*
Denver Radium (Card Corp.)*
Denver Radium (Open Space)*
Rocky Mountain Arsenal
Phoenix-Goodyear Airport
Operating Industries Inc. LF
San Fernando Valley
San Gabriel*
Stringfellow Acid Pits*
Colbert LF
State
MN
OH
OH
WI
WI
LA
LA
OK
OK
TX
TX
TX
MO
MO
MO
CO
CO
CO
CO
CO
CO
CO
AZ
CA
CA
CA
CA
WA
Region
5
5
5
5
5
6
6
6
6
6
6
6
7
7
7
8
8
8
8
8
8
8
9
9
9
9
9
10
NPL
Rank
39
164
492
414
190
731
196
483
761
639
450
728
Gr 15
474
474
157
284
284
284
284
284
Gr 2F
254
71
343
341
32
356
Lead
PRP
F
F
PRP
F
F
F
F
F
F
F
F
PRP
F
F
F
F
F
F
F
F
ENF
ENF
ENF
F
F
F
F
Pag:
306
309
311
314
317
320
323
326
328
331
333
335
338
340
343
346
349
352
355
358
361
364
367
370
372
374
377
380
 * Subsequent operable  units.

** Two  adjacent sites with one ROD.
                                         163
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                 Progress Toward Implementing Super-fund:  Fiscal Year 1987


                               DAVIS LIQUID SITE
                           SMITHFIELD, RHODE ISLAND


HRS Score: 4725                                                      NPL Rank: 216

Background

     The Davis Liquid site covers 15 acres and is  located in a  rural  section of
the town of  Smithfield  in Providence County, Rhode Island.  Although the  site
is bounded  by  forest and wetlands,  the area  is  under increasing Low-density
residential  use;  there  are 100 homes  within one  mile of  the  site.   Areas of
natural  resource  importance in  the  vicinity of  the  site include surrounding
wetlands, the  aquifers underlying  the site  damage  area,  and the  Stillwater
Reservoir.   The wetlands  provide habitat for many plant and  animal species and
the aquifers are tapped  by local residents as their sole source  of water supply.
Stillwater Reservoir is a Class  B water body and a potential water  supply for
the Town of Smithfield.

     The site served as a disposal  location for a variety of liquid and solid
wastes throughout the 1970s.   Drummed wastes and bulk liquid wastes from  tank
trucks were  dumped into  the unlined pits and lagoons at  the site.  In L978, after
a tire fire  at the site and subsequent investigation,  approximately six to eight
residents brought their concerns to  the Smithfield Town Council.  A court order
in 1978 prohibited the disposal of hazardous waste at  the  site.  At  that time,
State  efforts  to gain  access to  the  site  were  met  with a  series of legal
challenges by Mr. Davis, the site owner, which resulted in delays in  addressing
the contaminants  on  site.  A  group  of citizens  lobbied  the Town Council for
closure of the site and initiated legal and investigative action against the  site
owner.

     In 1980, the Rhode Island Department of Environmental Management (RIDEM)
conducted a full-scale ground-water  contamination study of monitoring wells on
the Davis property and  surrounding  residential properties.  Contaminants were
found  in both  the ground-water  wells  on and  off site and  the  surface water
adjacent to the Davis site.  A finding  of contaminants at  concentrations above
EPA health  and  safety criteria  prompted  RIDEM  to  supply bottled water to
residents using the affected wells.

     EPA and the State of Rhode Island signed a cooperative agreement to initiate
a State  lead remedial  investigation/feasibility  study  (RI/FS).   The site was
placed on the NPL  in September 1983.  The RI was completed by EPA in November
1986,  following initial work by RIDEM.  The  FS was released  for public comment
in  July  1987.   The  ROD   was  signed  September  29,  1987.    Approximately 26
potentially  responsible  parties  (PRPs)  were  issued  General Notice  Letters
encouraging  them  to  perform the response activities  necessary to cleanup the
site.   Negotiations with  the PRPs are  currently ongoing.
                                      164
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


Description of Site Work

     In 1985, the U.S. Government brought action against the members of the Davis
family to  ensure access for EPA to complete  the  RI/FS.   During the  winter of
1985, EPA  removed approximately 600  drums containing  hazardous  wastes.   The
wastes disposed of at the site include neutralized wastes from incinerated toxic
materials, drums containing chemical and sewage sludges, waxes and liquids,  and
liquids that included organic solvents.

     Data  from  the  RI indicate  that  significant  quantities  of  hazardous
substances remain on site following the removal actions.  Contamination was found
in  the  soil,  ground water,  surface  water,   and sediments  on site,  in  the
overburden and bedrock  aquifer,  and in the ground water and  surface  water  off
site. Volatile  organic  contaminants such as trichloroethylene (TCE) toluene  and
xylene were found  in high concentrations.  Inorganic  contaminants  included lead
and nickel at concentrations in excess of Federal  aquatic toxicity criteria  for
chronic effects.  The filling of wetlands with debris (e.g. tires)  has  increased
water levels at  the site, threatening  the  wetlands vegetation.

Description of Feasibility Study

     The objective of the  FS was to  develop  alternatives for  controlling  the
source of  contamination and preventing further migration of  the  contaminants.
Alternatives were  evaluated with regard to CERCLA criteria.  The  alternatives
comprised  two  types  of remedies:    source control  (soil)  and management  of
migration  (ground  water,   surface  water,  and  sediments).    The  following
alternatives were  considered:

     (1)  No action alternative;

     (2)  Source control alternatives  --

          •    on-site  low-temperature  thermal  soil  treatment,"

          •    on-site  thermal destruction; and

          •    off-site thermal destruction.

     (3)  Management of migration alternatives  --

          •    on-site  treatment of the  ground water  and  construction  of  an
               alternate water supply;

          •    combined treatment of contaminated surface water in the  ground-
               water treatment system;  and

          •    off-site sediment dredging  and  treatment.

     In general,  those  commenters  that submitted formal  written and/or oral
comments supported EPA's preferred alternative (see below).   Community interest
was high  concerning the investigation of contaminated  residential wells  and
public meetings  were held  on  the results of the RI  and the  FS.   Since  the
                                      165
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


completion of  the  draft FS,  most commenters had  major  concerns regarding  the
safety of air emissions from the incineration process.

Description of Selected Remedy

     The  selected  remedial  action  is  a  comprehensive   approach  for  site
remediation.   The  source  control  component includes excavation  of waste  and
soils, treatment by  thermal  destruction,  and disposal  in  an on-site Resource
Conservation and Recovery Act (RCRA)  Subtitle C  landfill.   Surface-water runoff
and ground-water recharge to the stream on site  will be  isolated for collection
and treatment.   Wetlands disturbed by the remedial action will be restored.   The
management of  migration component  includes  the design  and construction of  an
alternate water supply,  and the  design  and construction of  a  ground-water
extraction,  treatment, and flushing system.

     Major applicable or relevant and appropriate requirements (ARARs) considered
included  RCRA  closure  performance  standards   and  ground-water  protection
requirements,  the  Clean  Water  Act  (CWA),  Safe  Drinking Water Act (SDWA),
Executive Order 11990 for Protection of Wetlands,  Toxic Substances  and Control
Act (TSCA),  and  the  Clean  Air Act  (CAA).   Also, the remedy must be consistent
with EPA Ground-water Protection Strategy,  as the aquifer  at  the site is Class
II  and requires  restoration.   State  ARARs include  the  RIDEM  ground-water
protection rules and regulations, and the Rhode Island Wetland  Protection Act.

     The  selected  remedy  is  expected  to  meet  ARARs,  complies with CERCLA's
statutory preference  for  a  remedy  that  significantly  reduces  the volume,
toxicity, or  mobility  of hazardous  substances,  uses  alternative  treatment
technologies,  is cost-effective, and represents a permanent solution.
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                               OTTATI AND GOSS/
                   GREAT LAKES CONTAINER CORPORATION SITE
                           KINGSTON, NEW HAMPSHIRE


HRS Score: 53.41                                                      NPL Rank: 130

Background

     The Ottati  and  Goss/Great Lakes  Container  Corporation  (O&G/GLCC) site is
located  on  approximately 35 acres  in Kingston, New  Hampshire.   The  O&G/GLCC
comprises seven  non-contiguous acres  on  the  site.   Since the late  1950s,  the
site has been used by several companies for the reconditioning of disposal drums
and for  the disposal  of hazardous waste.    Caustic  rinse  solutions  from  the
reconditioning operations were released onto the site, and heavy sludges were
brought  to  the  site  for  processing,  beginning in  1978.    Volatile organic
compounds (VOCs), acid and base/neutral  (ABN) compounds,  PCBs,  and metals have
contaminated ground  water,  surface  water, and soils on the site.  Some  of the
contaminants present, such as benzene, arsenic, and TCE, are known or suspected
carcinogens.  Individual residential wells derive ground water from  aquifers in
the area, although no residential well contamination has been attributed  to the
site.

     On July 1,  1979, the New Hampshire Bureau of Solid Waste Management ordered
the  operators  of  the   site  to  remove  waste drums  and to  cease   processing
operations.   A  subsequent response action  involved excavation and  removal of
12,800 tons of drums and contaminated soils.   The O&G/GLCC site was placed on
the NPL  in  September 1981.   The remedial investigation  (RI) initiated in 1983
indicated contamination  of  soil, surface water,  ground water, and  sediments.
In an effort to compel private parties  to respond to the contamination, EPA filed
a complaint in May 1980.  The  court concluded in 1985  that  a number  of parties
are liable  for  the hazardous substances  present at  the site.   The  outcome of
settlement proceedings, and  the determination  of responsibility for remediation,
were not known at the time the ROD was signed on January  16, 1987.

Description of Site Work

     The State lead  RI/FS  for  the site  was completed in August 1986.   The RI
indicated high concentrations of VOCs, PCBs,  ABNs,  metals, and  cyanide  in soils
at  numerous locations   on  the  site.    VOCs  and  metals  are  the  principal
contaminants in  the ground water, and evidence  suggests  these  compounds  may be
migrating off site.   EPA believes that the soil contamination presents  a  direct
contact  risk,  along with risks from ingestion of contaminated  ground water.

Description of Feasibility Study

     The feasibility study (FS) was conducted in 1986  to  evaluate remedies  for
the O&G/GLCC site.   EPA  eliminated  12 of the initial 18  remedial alternatives
during an initial screening phase. The remaining  six alternatives were evaluated
on the basis of  engineering practice, protection  of public health  (including
extent of compliance  with ARARs), the use of alternative technologies, and cost.
These six alternatives  were as follows:
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          (1)  No action,  with site monitoring  and restricted land
               use;

          (2)  Ground-water interception trench, on-site disposal of
               wastes,  Resource Conservation and Recovery Act (RCRA)
               site cap,  and source control;

          (3)  Alternative  2   plus  ground-water   extraction  and
               treatment;

          (4)  Alternative 3 plus alternate water supply;

          (5)  Removal of contaminated soils and sediments to a RCRA
               facility;  and

          (6)  Treatment   of   soils  and   sediments,   ground-water
               treatment,  and site cover.

     Evaluation of the alternatives included consideration of their compliance
with potential applicable  or relevant and appropriate requirements  (ARARs).  The
use  of a  RCRA  cap  would require  compliance  with RCRA  standards,  and the
remaining waste on site would  make  RCRA  closure and post-closure requirements
relevant and  appropriate.   The  Toxic  Substances Control  Act (TSCA)  disposal
standards for PCBs would also apply, as would requirements governing  the removal
of sediments from wetlands. The removal  of  wastes off site would be subject to
RCRA and TSCA transportation and disposal regulations.  The treatment of ground
water, or destruction of contaminated soil by incineration, would also have to
conform to Federal standards.

     EPA held two public comment periods between September and December  1986 for
interested parties to comment on the draft FS and the preferred alternative (see
below).  A third comment period,  allowing for public response  to a ground-water
model  of the  site, began  in late December 1986.   Local  citizens and local and
State  officials  were actively  involved  with  site  activities.   New Hampshire
environmental  authorities  have collaborated with EPA personnel  since  1981 in
collecting and analyzing data.

Description of Selected Remedy

     The preferred alternative, combining elements of several  remedial  options,
includes  excavation  and   incineration  of  selected  PCB-contaminated soils,
aeration  of  14,000  cubic yards of  soil  to  remove VOCs,   and  ground-water
extraction, treatment,  and monitoring.   EPA believed that both source control
and  ground-water  remediation  were necessary to protect  public  health and the
environment.   The source control  alternative  is  necessary to  minimize the
migration of contaminants  into ground water  and  the  risk  associated with direct
contact to the soils.  This phase of the remedy uses incineration and  aeration
of VOCs,  the  latter of  which  is considered an  innovative  technology.   EPA
believes  that treatment  of  the  hazardous  substances will  be  effective and
reliable over  the long term in minimizing risk.   EPA's  decision is consistent
with  the  statutory  mandate   of CERCLA  to  select permanent  solutions  and
alternative treatment technologies to the maximum extent practicable.
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                               RESOLVE, INC., SITE
                             SECOND OPERABLE UNIT
                       NORTH DARTMOUTH, MASSACHUSETTS

HRS Score: 47.71                                                      NPL Rank: 206

Background

     The Resolve, Inc.,  site is  located  in North Dartmouth,  Massachusetts,  about
8 miles  west of  Fall  River.   The 6-acre site  was used  as  a waste chemical
reclamation facility from 1956 to 1980.   The land surrounding the site primarily
is zoned for residential use,  and all  of the  nearby residences obtain  their
drinking water from private wells.   The  nearby Copicut River drains into Cornell
Pond, a popular sport-fishing area.

     During its operation as a chemical reclamation facility,  the site received
solvents, waste oils, organic liquids and solids,  inorganic liquids and solids,
and PCBs.   Resolve disposed of the hazardous  byproducts from  its reclamation
processes  either  in one  of four unlined  lagoons  located on  the site,  or by
landfarming, a method by which wastes  are spread  into the soils of the  site.
In 1974, the Massachusetts  Division of  Water Pollution Control  granted Resolve
a license  to collect hazardous  waste from 1974 to 1980.  However, in December
1980 Resolve surrendered its license after the  Department discovered  violations
of the license provisions.   Investigations conducted  by the Department at  that
time showed no migration of contaminants from the four lagoons.  Resolve removed
drums, buildings, and loading and unloading pads in 1981, but  did not empty the
contents of  the  lagoons.   When leaching of wastes was  discovered in 1982, EPA
placed the site on  the NPL.

     EPA initially  divided remedial activities at  the site into two operable
units.  EPA initiated a remedial investigation (RI)  for the first operable  unit
in the  fall of  1982 to  assess the  extent  of  on-site source  contamination.
Following  the completion  of this RI in June 1983,  EPA  undertook  a feasibility
study  (FS)  that  recommended  source  material  be  excavated  and the  site be
encapsulated.  A ROD for  the on-site operable unit was  signed on July 1,  1983.
From September 1985 to  February 1986,  EPA conducted  the RI/FS for  the second
operable unit to assess off-site contamination.  In April  1985,  before the ROD
for the  off-site  operable unit was signed, EPA became aware  that on-site PCB
contamination was more  extensive than originally believed, and  that PCBs  were
migrating  off site.  In September 1985, EPA initiated  a comprehensive on- and
off-site RI/FS to determine the extent of the  PCB contamination.   EPA completed
this comprehensive  RI/FS  in February 1987 and the ROD  was signed in September
1987.

Description of Site Work

      The  results   of  the  final,  comprehensive RI  indicated  that  PCBs   were
present  in on-site  soils  in  significant concentrations  despite the  earlier
removal action, and that,  as a result of their having dissolved in solvents  that
were also  located in the  soil,  PCBs were migrating through ground water toward
the Copicut River.   EPA also identified  other hazardous constituents of concern,
including methylene chloride, 2-butanone, and toluene.   The four  major sources
of contamination at the site were located primarily around  the lagoons.  The RI


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concluded that these sources had contaminated on-and off-site  ground water  and
off-site surface water, in addition to the soil.

Description of Feasibility Study

     The comprehensive FS  identified  remedial actions  that  would result  in
source control and stop the migration of contaminants.  Seven  remedial  options
remained after a preliminary screening:

     (1)  No action;

     (2)  On-site  thermal  destruction  of  64,000  cubic   yards  of
          contaminated soils;

     (3)  On-site dechlorination of 64,000 cubic yards of contaminated
          soils;

     (4)  Encapsulation of the site,  in situ  flushing of contaminated
          soils,  and treatment of source materials having the highest
          concentrations of PCB contamination;

     (5)  Off-site thermal destruction of contaminated soils;

     (6)  On-site treatment of ground water; and

     (7)  Heated influent air stripping of ground water.

     The FS also  identified applicable  or relevant and  appropriate requirements
(ARARs) for each of  the  remedial alternatives.   These ARARs included Resource
Conservation and Recovery Act  (RCRA)  disposal and closure  requirements,  Toxic
Substances and Control Act (TSCA) PCB cleanup standards, Safe Drinking Water  Act
(SDWA) Maximum Contaminant Levels (MCLs), and Department of  Transportation (DOT)
regulations for the transportation of hazardous wastes.

     Citizen involvement  in the RI/FS  and selection  of  remedy processes  was
substantial.   EPA  held several  public  meetings to  explain the remedies,  and
actively encouraged the development of  a Citizen's Advisory Committee.  Several
commenters commended EPA for selecting an innovative technology to remediate  the
Resolve site  (see  next section for description).   The State  of Massachusetts
al-so was consulted and concurred with the remedy  selected.

Description of Selected Remedy

     The remedy  selected  (Alternative  3) addressed both  source control  and
prevention of the migration  of contaminants.  Specifically,  the remedy included:

     •    Excavation of 22,500 cubic yards of PCB-contaminated  soils,
          treatment in a mobile dechlorination unit to achieve a level
          of cleanliness corresponding to 25 parts per million (ppm)
          PCBs, and replacement of the treated  soil  on site;
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     •    Excavation   of  3,000  cubic  yards   of   PCS-contaminated
          sediments  in  wetland resource  areas  and  treatment in  a
          dechlorination unit  to  achieve 1 ppm PCB;

     •    Restoration of ground water using on-site air stripping and
          carbon absorption; and

     •    Placement of institutional controls on ground water  that
          cannot be  adequately cleaned  to achieve a drinking  water
          standard.

     This remedy uses  an  innovative  technology  (i.e.,  dechlorination)  and is
expected  to  satisfy the CERCLA mandate for protecting human health  and  the
environment,  attaining  all ARARs,   and  permanently  reducing  the  toxicity,
mobility, or volume of hazardous  substances.
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               BROWNING-FERRIS INDUSTRIES (BFI) SOUTH BRUNSWICK
                                 LANDFILL SITE
                         SOUTH BRUNSWICK, NEW JERSEY

HRS Score: 53.42                                                      NPL Rank: 125

Background

     The Browning-Ferris Industries (BFI) Landfill Site is located approximately
1/2 mile northwest of Route 1  in South Brunswick,  New  Jersey.  The  landfill
occupies approximately  68 acres  and is surrounded  primarily by wooded  land,
although residences and a school are located nearby.   The site also  is  close  to
Heathcote Brook, a tributary of the  Millstone River,  which  occasionally  serves
as a source of drinking water for the City of New Brunswick at a point  10 miles
downstream.

     The BFI site was a solid waste  landfill  for approximately 20 years  before
it was closed  in 1978.   It received municipal,  hazardous,  and chemical  wastes
and pesticides  during the time it was  open.   BFI  acquired the site from G.J.
Spilatore  Excavation Company  in May  1973; both  parties  were  identified  as
potentially responsible parties  (PRPs), although BFI took  full responsibility
for the remediation process.

     EPA conducted an investigation of the site in June 1980.   In 1982, EPA and
BFI entered into a three-stage Consent Order agreement to  remediate the  site.
Phase I of the plan called for BFI to conduct a remedial  investigation (RI)  of
the site, which was  completed  during 1982.  The site was listed  on the  NPL  in
December 1982.   Phase II of the  agreement required  BFI  to develop a  remedial
plan and construct an EPA-selected remedy;  BFI completed  this  phase  between May
1983 and September 1985.   Phase  III required BFI  to conduct  a  post-remedial
environmental monitoring program, which BFI proposed in June  1987.  Because  of
the Consent Order, no feasibility study (FS)  was ever conducted  for the  site.
When BFI proposed  Phase III of  its program, EPA developed the ROD to determine
whether  the  remedial action selected  in 1983,  before the  SARA  amendments  to
CERCLA, was consistent with the new  statutory requirements.

Description of Site Work

     The RI conducted by BFI indicated  that a shallow aquifer beneath  the site
was contaminated with  total  volatile  organics  (TVOs).   Because some of the
bedrock underlying this upper aquifer was  fractured,  a deeper aquifer  also had
become contaminated with TVOs.   The RI also discovered that leachate  was seeping
from one side of the  landfill and migrating toward Heathcote  Brook.

Description of Feasibility Study

     Because the PRP  had developed the  remedial actions,  EPA  did riot develop a
formal FS.   Instead,  the ROD  included  EPA's  analysis of alternative  remedial
actions,   in which EPA  screened  available  technologies  and identified the
following nine options  to be evaluated  against the criteria of CERCLA:

     (1)   No action;
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     (2)  Leachate collection system;

     (3)  Leachate collection system and clay cap;

     (4)  Slurry wall constructed to the depth of  bedrock beneath the
          site;

     (5)  Slurry wall constructed to the depth of bedrock  and clay cap;

     (6)  Slurry wall constructed to the depth of residual soil;

     (7)  Slurry wall constructed to  the  depth  of residual soil and
          clay cap;

     (8)  Slurry wall constructed both to residual soil and to bedrock
          and a clay cap; and

     (9)  Slurry  wall constructed  both  to  residual  soil   and  to
          bedrock, a clay cap, and a leachate collection system.

     The  analysis  also  identified  applicable  or  relevant  and  appropriate
requirements (ARARs) that remedial actions must meet.  ARARs identified for this
site included  Resource Conservation and  Recovery Act  (RCRA)  regulations for
closure of hazardous  waste  landfills,  the Clean  Water Act (CWA)  pretreatment
standards for discharge to publicly owned treatment works (POTWs), and  Executive
Order 11990 for the Protection of Wetlands.  A New Jersey  State Administrative
Code requirement  for  capping of landfills also was  identified  as  an ARAR for
the site.

     The New Jersey Department of Environmental Protection (NJDEP) agreed that
on-site  containment  of  the  contamination  and  monitoring  of  the  site  are
protective of human health  and  the  environment,  and concurred with the remedy
selected.    Concerned citizens  were  informed  of  the  remedial  action  and
monitoring requirements of  the BFI plan, and EPA held a public  meeting  on August
6, 1987, to explain  the long-term monitoring plan and discuss  the success of the
constructed remedy.   Overall, the  public  and local  officials  have  expressed
satisfaction  with  the  selected  remedy and  the  timeframe   in  which  it  was
implemented.

Description of Selected Remedy

     The  remedy selected  for the  site  in  1985  by  BFI  was  Alternative  9,
construction of a slurry wall to  the  depth of bedrock beneath the portions of
the site where  it is  relatively  shallow and  to  the depth of residual soil for
the remainder of  the  site.   The remedy also included placement of a clay cap
over the site and the  construction  of  a leachate collection system.  Leachate
collected at the site was treated at a nearby wastewater treatment plant.  The
treatment  was  selected  on the  basis  of  its  implementability  and  proven
effectiveness.   Treatment  of the hazardous  waste buried at  the  site was not
feasible  because discrete  areas of  hazardous  waste  disposal  could  not  be
identified, and excavation and treatment of the entire  68 acres was determined
not to  be feasible.   The  selected remedy  complies  with the  preference for
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treatments  that  reduce  the  toxicity,  mobility,   or   volume   of  hazardous
constituents because the leachate collection and wastewater treatment processes
are reducing the amount of hazardous  constituents  at  the  site.

     The evaluation of the remedial alternatives in the ROD concluded that this
remedy best meets the requirements of CERCLA.  The remedy was judged to be cost-
effective and protective of human health and  the environment.  The  remedy also
meets Federal ARARs for capping and the pretreatment standards for discharge to
POTWs.     The  remedy  does  not  meet  the   requirements   of  the  New  Jersey
Administrative  Code  for capping, but EPA waived  this  State ARAR  because  the
selected  remedy is  achieving a  standard  of performance  equivalent to  that
required by the State regulation.
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                     CHEMICAL CONTROL CORPORATION SITE
                             ELIZABETH, NEW JERSEY


MRS Score:  47.13                                                      NPL Rank: 223

Background

     The Chemical Control  Corporation  (CCC)  site  is located in Elizabeth, New
Jersey, on  a peninsula  formed by  the  Elizabeth  River and  the  Arthur Kill.
Despite a  ban by  the  State  of  New Jersey since  1980,  recreational fishing
continues within 3/4 of a mile  from the site, and both water bodies are used for
commercial purposes.

     Chemical  Control   Corporation  operated  between  1970 and  1978  and was
involved  in  the business  of  hauling,  treating  and  disposing  of  industrial
wastes.   Throughout  its  operations,  CCC  was  cited  for violations  such as
illegally discharging liquids and accumulating drums that contained incompatible
wastes.  In  1978, the  Corporation was  placed into operational receivership by
the Superior Court  of  New  Jersey.   The  State of New Jersey began  a  cleanup of
the site in  March 1979.  The  cleanup included removing solids, liquids, nearly
10,000 drums of waste,  10 pounds of infectious wastes,  7 pounds of radioactive
wastes, and  24 gallons  of  explosive  liquids.   In April 1980,  an explosion and
fire occurred at the site that were not brought under  control for  more than 10
hours.  After the fire,  New Jersey continued its cleanup of the site by removing
buildings, drums, tanks, and surface soil.   The State also operated  a ground-
water recovery and treatment  system at the site from November 1980  to  July 1981.

     In 1981,  the  site was  ranked for  inclusion  on the  Superfund Interim
Priorities List.  EPA  has  conducted two Initial Remedial Measures (IRMs)  that
included  decontaminating  and  removing  trailers  from the  site, cleaning   a
contaminated sewer  line,  and recovering containers  from the  Elizabeth River.
A final IRM  has  been proposed to remove deteriorating gas cylinders from the
site.   Drums of  waste  currently remain on  the  site,  which is surrounded  by  a
security fence.

     The EPA lead remedial investigation  (RI)  was completed in July  1986, and
the results  of  the  feasibility study (FS) were released in June  1987. Notice
letters were sent in August 1987 to 31 parties identified  as generators of the
wastes or potentially  responsible  parties  (PRPs).   Informal  discussions  with
the PRPs  to reach  a  possible  settlement  continue.    The ROD was  signed on
September 23, 1987.

Description of Site Work

     Following the first two IRMs,  EPA initiated an RI  to  determine  the extent
of soil,  ground-water,  and  river contamination on the site, as  well as the human
health risks associated with that contamination.

     The RI  indicated  that  soil and  river  sediments are  contaminated  with
organic compounds and,  to a lesser degree, with metals.  The RI also  found low
concentrations of contaminants in the ground water.
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Description of Feasibility Study

     The  EPA  lead feasibility  study (FS)  was  completed  in June  1987.   The
objectives for  the remedial  action,  developed in  the  FS, were  based on the
findings of the RI.  The RI  identified the presence  of highly  contaminated soil
as posing the greatest potential risk to the public  health  and the environment.
The objective of the  remedial action,  therefore, was to  reduce the mobility and
toxicity of the contaminants in the soil, protect  against human  exposure  to the
contaminated soil, assure that leaching of contaminants from  the soil will not
increase, and return the site to a condition consistent with  future industrial
development  in  the  area.    The  following  eight  remedial  alternatives were
considered:

     (1)  No action;

     (2)  Containment using a ground-water barrier;

     (3)  In situ soil washing with a ground-water barrier;

     (4)  In situ soil  fixation;

     (5)  Excavation and off-site disposal to a landfill;

     (6)  Excavation, on-site treatment, and off-site disposal;

     (7)  Excavation, on-site treatment, and on-site disposal;  arid

     (8)  Excavation, off-site incineration, and disposal.

     Evaluation  of  the alternatives considered  applicable  or  relevant and
appropriate  requirements  (ARARs),  and also  considered  the  utilization   of
permanent solutions and alternative treatment technologies.   Federal and State
ARARs identified included Executive  Order  11988  for Management of  Floodplains
and  discharge  limits  for  surface-water protection.   Another ARAR  was the
Endangered  Species Act  because the  surface water near  the  site  is  within
breeding range of the endangered short-nosed sturgeon.  New Jersey has indicated
that  State ARARs will be  satisfied  if   a  bioassay  is  performed,   and   if
contaminants  in  the  soil are found not  to  exceed State guidelines.  Resource
Conservation and Recovery Act (RCRA)  regulations were not considered applicable
because the site did not operate under a permit  issued pursuant to that act.
However, the selected remedy was evaluated for compliance'with RCRA,  as relevant
and appropriate, by considering the hypothetical situation of a  site similar  to
Chemical Control  that was operated under a permit.

     Input received  during  the  public  comment period was  considered in the
decision.  Community concern began in  1977 when  citizens and  local officials
complained about the site.   The  main  concern of  local  officials is  that  a
thorough, permanent remedy be implemented expeditiously.
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Description of Selected Remedy

     The selected remedy  is  the  in situ soil fixation alternative  (Alternative
4) that includes repairing berms on the site,  removing debris,  sealing the sewer
line,  and  monitoring  to  evaluate  the effectiveness  of  the remedy.   In situ
fixation  of  the  soil  meets CERCLA  requirements  to reduce  the  mobility  of
toxicants, provide  a permanent and long-term  solution,  and use an alternative
treatment technology that offers a cost-effective remedy.   The  on-site operation
may temporarily violate Executive  Order 11988  for the Management of Floodplains
while equipment is located on the site. Both the Department of Commerce and the
Agency for  Toxic  Substances and  Disease  Registry concurred that the selected
remedy offers adequate protection of  public health.
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                            COOPER ROAD DUMP SITE
                        VOORHEES TOWNSHIP, NEW JERSEY


HRS Score: 36.79                                                      NPL Rank: 473

Background

     The Cooper  Road  Dump site is  located in Voorhees Township  in the north
central part of Caraden County, New Jersey.   The dump encompasses a  surface area
of less than 100 square feet.  The area around the site is being developed for
residential use, with the closest house within 300 feet of the site.  Aquifers
supplying  drinking  water underlie  the site  and  there are  several potential
surface-water discharge points from the aquifer in the vicinity.

     Contamination was  discovered in  mid-1982 when several  dozen broken and
sealed small glass vials containing liquid chemicals were found partially buried
in a soil  pit area.  An  analysis  of the  vials by  the New Jersey Department of
Environmental Protection (NJDEP) indicated the presence of hazardous substances,
including benzene,  xylene, and naphthalene.  The NJDEP subsequently ordered the
owner  of   the property  to  remove the hazardous  materials  but  no  reply was
received.

  A  surface cleanup  was  completed in  May  1984 by  a new  site  owner,  the
Cinamerican Company,  during which  all the vials and soils to a depth of 6 inches
below  any  vials were  removed.   Although  no  further  soil  contamination was
revealed,   the  site  was  placed  on  the   final  NPL   in  November  1984  for
determination by EPA as  to whether there had been a release  of  contaminants into
the underlying  soils  or ground water.   In September 1986,  EPA  arid the NJDEP
agreed to conduct sampling at the  site, and the sampling reports were completed
in August  and September 1987.  The ROD was  signed September 30, 1987.

     No additional enforcement actions are anticipated because the generators
of the vials have not been located, the vials appear to have been dumped without
the knowledge  of the  previous or  current property  owners,  and  the   current
property owner completed a surface cleanup  to  the satisfaction of  EPA.

Description of Site Work

     Results  of the  soil and ground-water sampling  in  April  1987 revealed
certain  contaminants at  concentrations  above background  levels.   However,
because  contamination was  found  at  the  laboratory where  the  samples  were
analyzed,  the validity  of  the  sampling  studies was  called  into question.
Further  EPA testing  revealed no  contaminants in  concentrations  that would
produce any  adverse health  effects,  based  on Federal and State guidelines and
criteria.   The  risk assessment in  the remedial investigation (RI) determined
that there was no potential exposure to contamination.
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Description of Feasibility Study

     Because the field investigations indicated no contamination, no potentially
feasible  remedial actions  were  evaluated.    It was  also determined  that no
monitoring of the  shallow underlying aquifer was necessary.

     Applicable or relevant and appropriate requirements  (ARARs) identified for
the ground water at the site were EPA's Maximum Contaminant Levels (MCLS) under
the  Safe  Drinking Water Act  (SDWA),  and NJDEP'S  Interim  Action  Levels  for
Selected Organics  in  Drinking Water.   Action levels for certain metals in soil
have been developed by  NJDEP and were used as ARARs.  No contaminants exceeded
ARARs.

     Community  involvement  was  solicited at  the  conclusion  of  the RI  and a
public meeting was held in September 1987.  Town officials and  citizens who live
in the vicinity of the  site attended the  meeting.   Since the  discovery of the
site  in  1982,  community concern has  focused  on  potential  health  effects of
community exposure, potential adverse effects  on housing values, and the timing
of the removal of  the site  from the NPL.

Description of Selected Remedy

     The remedy selected for the site calls for no further action.  The remedy
is considered to comply with ARARs,  to be cost-effective, and to be protective
of human health and the environment.
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                              DIAMOND ALKALI SITE
                    (ALSO KNOWN AS DIAMOND SHAMROCK SITE)
                        SOURCE CONTROL OPERABLE UNIT
                              NEWARK, NEW JERSEY


HRS Score: 35.40                                                      NPL Rank: 523

Background

     The Diamond Alkali Site (also  known as  the  Diamond  Shamrock Site)  is
located in Newark, New Jersey, along  the Passaic  River.  The  3.4-acre  site has
been used  for industrial purposes  since   the  1870s.   From  1951  to 1969, the
Diamond Alkali Company (subsequently known  as  the  Diamond Shamrock Chemicals
Company) manufactured  DDT  and other  chemicals on  the site,  including  sodium
trichlorophenol  (TCP).   After 1969,  the  site was  owned  or leased  by  several
companies.

     During 1983, as a  result of  EPA's  strategy to inspect all sites  known  to
have produced TCP,  the site was sampled for dioxin contamination.  The  tests
showed that dioxin contamination was present, and in March 1984,  the  New Jersey
Department of Environmental  Protection  (NJDEP) issued an Administrative  Order
to  Diamond Shamrock  to conduct  a  remedial  investigation/feasibility  study
(RI/FS).  The site was  listed on the NPL in September 1984  and Diamond  Shamrock
completed the RI/FS in December 1985.

     EPA and NJDEP divided the site into operable units based on the  results  of
the RI conducted by Diamond Shamrock.  The  first operable unit addressed source
control and remediation  of  ground water.   EPA made public a  proposed  remedial
action plan in July 1987.  After responding to public comments,  the ROD for the
first operable unit was signed in September 1987.  Subsequent operable units may
address remediation of  ground-water contamination,  and the remediation  of the
sediments of Passaic River.

Description of Site Work

     Diamond Shamrock completed the RI in  May 1985 under the supervision of the
NJDEP.  The  RI  included sampling  of air, ground water,  soil,  surface  water,
buildings on the  site,  storage drums,  arid off-site properties.  The RI indicated
that the site was  contaminated by  a large number of hazardous  substances, and
that the greatest risks were posed by DDT  and dioxin.   The  pathways of  exposure
determined to cause risk included:  migration of hazardous substances to surface
water  and  sediments of the  Passaic River;  migration of  airborne hazardous
substances from  volatilization and dust generation;  and migration of hazardous
substances into  the ground water.

Description of Feasibility Study

     The FS  for  the first  operable unit  evaluated remedial alternatives for
source  control,   including  the prevention  of  further releases  of hazardous
substances to the Passaic River.  Seven remedial  alternatives were developed:

     (1)  No action;


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     (2)  On-site containment of wastes with  a  cap  and  slurry  wall;

     (3)  On-site containment of wastes with a cap and slurry wall and
          ground-water treatment;

     (4)  Excavation  of  wastes  and  on-site  thermal   destruction,
          containment of remaining wastes with a cap and slurry wall,
          and on-site ground-water treatment;

     (5)  Excavation of wastes  and construction of an  on-site  vault
          encapsulating all wastes and on-site ground-water treatment;

     (6)  Excavation of wastes  and off-site disposal, containment of
          remaining wastes with a cap and slurry wall,  on-site ground-
          water treatment,  and  decontamination  of buildings; and

     (7)  Excavation  of  wastes  and  off-site  thermal  treatment,
          containment of remaining wastes with a cap and slurry wall,
          on-site  ground-water  treatment,  and decontamination  of
          buildings.

Description of Selected Remedy

     The  remedy selected  was  similar  to  Alternative   3  of  the FS,   on-site
containment  of  wastes with a  cap  and  slurry  wall  and on-site  ground-water
treatment.   The remedy was  expanded to include protection against floods  with
the construction of a flood wall, off-site  removal  of certain  drums  located on
the site, and requirement for a follow-up  FS  every  2  years.

     The  remedy is expected  to attain all ARARs  except  the  three  that  were
waived in accordance with  CERCLA section 121(d)(4)(B), that allows a waiver from
meeting an ARAR when attaining  the ARAR will  result in  a greater risk  to  human
health  or the  environment.  ARARs  not met  for this  reason  were  RCRA  land
disposal  restrictions  and  landfill design requirements, and State  landfill
design requirements.

     The remedy is expected to be protective of human health and the environment
consistent  with the  requirements  of  CERCLA.   The  State  of  New Jersey  was
consulted and concurred with the selected  remedy.
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               MONTGOMERY TOWNSHIP HOUSING DEVELOPMENT SITE
                    ALTERNATE WATER SUPPLY OPERABLE UNIT
                      MONTGOMERY TOWNSHIP, NEW JERSEY


HRS Score:  37.93                                                     NPL Rank:  438

Background

     The Montgomery Township Housing Development (MTHD)  site is a 72-acre tract
of land  located  in  Montgomery Township,  New  Jersey,  15  miles  northeast  of
Trenton.    There  are  77  homes  located on  the  site.    Each home has  its own
drinking water well that draws water from the Brunswick Formation aquifer that
underlies the site.  Ground water in the  Brunswick formation is also used for
industrial purposes.

     In 1978, a Rutgers University study of the Rocky Hill  Boroug,h well, which
is  located  nearby but  not  within  the  MTHD,  revealed  that  the  well  was
contaminated with  trichloroethene (TCE).   In  1979, after continued testing of
this  water  supply  indicated  greater TCE  concentrations,  the  New  Jersey
Department of Environmental  Protection (NJDEP) began  sampling  commercial and
domestic wells in Montgomery Township.  Included in the NJDEP sampling program
were private wells, industrial supply wells, soils, surface waters, and septic
tanks.   In August 1980,  Montgomery Township authorized  the  installation of
Elizabethtown Water Company  (EWC) water mains in the MTHD, and residents were
advised not to use well water.  As of September 1987, 38 residential wells had
been connected to water mains.

     In 1984, NJDEP entered  into  a  cooperative  agreement with EPA under which
NJDEP would perform the remedial investigation/feasibility study (RI/FS)  for the
MTHD and Rocky Hill Municipal  Well  (RHMW)  sites.   Because of the proximity of
the sites,  and  the similarity of the  contaminants found,  NJDEP performed the
RI/FS for the two sites under one cooperative agreement.  Due to the potential
health risks posed by the possible consumption of contaminated ground water, EPA
designated as an  operable unit  the  provision  of an alternate water supply for
the 120 residents of  the MTHD with private drinking water wells.  The State lead
RI/FS for this operable unit was completed in  July 1987,  and the ROD was signed
in September 1987. Remediation of the aquifer will be addressed  in a subsequent
operable unit ROD.

     The NJDEP  has not: been  able  to  identify  the precise  source  of the TCE
contamination, although several industrial and commercial establishments within
the site area,  including  an industrial research  facility,  are  believed to be
potential sources.  There is no conclusive  evidence, however, connecting these
PRPs to the TCE contamination.

Description of Site Work

     The NJDEP  separated  the  joint-site RI/FS  into  two  phases.   Phase 1, the
geohydrologic investigation, was completed  in January 1987.  The objective of
this phase was to characterize and determine the boundaries  of the ground-water
contaminant plume.   Results indicated  the  ground  water was contaminated with
TCE,  at levels up  to 650  ppb,  and with other  volatile organic compounds.  The


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TCE-contaminated  ground-water  plume,  which  appears  to have  been in a  steady
condition for  at least the  past  8 years, threatens  an area of  approximately
25,000 square feet.  The RI, however, could  not precisely  determine  the  extent
of the plume.

     The second phase of the RI  is continuing and is attempting to better  define
the contaminant  plume.    Remediation of  the aquif e"r  will be  evaluated in  a
subsequent FS.

Description of Feasibility Study

     The State lead FS for the alternative water  supply operable unit addressed
the health risks to the  120 MTHD residents who continue to  utilize contaminated
or  threatened  private  wells.     The  following  remedial  alternatives were
developed:


          (1)  No action, except for  ground-water monitoring;

          (2)  Temporary provision of bottled water to residents (for
               2 to 12 years);

          (3)  Extension of  the EWC Distribution System to  allow  for
               service connections  to all threatened residents,  and
               closure of individual  residential wells; and

          (4)  Construction  of  a new  centralized community well  and
               treatment of  well water.

     New Jersey Maximum Contaminant Levels (MCLs)  and Safe Drinking Water  Act
(SDWA)  MCLs  were  determined  to  be  applicable  or  relevant  and appropriate
requirements  (ARARs)  at  this  site.    Drinking  Water Health  Advisories  and
reference levels  for carcinogens  are not enforceable  requirements, but were
considered in the analysis of remedial alternatives.

     MTHD residents  showed  concern  about  the  site,  particularly  about  the
quality of EWC water.   However, EPA  and  NJDEP have  confirmed  that  this  water
supply  consistently  is  in  compliance  with  State  and Federal water quality
standards.   Several residents  also  expressed reservations about  the permanent
sealing of  their private  wells because  of  the expense  of  using  EWC  water.
Additionally, the Township and a number of residents believe that some residents
have been compensated  insufficiently in  the  past  for the  costs  of service
connection  installations.    EPA  responded  that  Superfund  is  not  used  for
reimbursement programs,  and  that future reimbursement of residents is an issue
for the State.

Description of Selected Remedy

     The alternative selected for  this  operable  unit (Alternative 3) included
extending the  EWC Distribution System,  providing service  connections  to  all
residents currently using wells that  are or  could be contaminated, and sealing
individual contaminated wells.  This  remedy  represents  the  first  operable unit
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                 Progress Toward Implementing Superfund: Fiscal Year 1987


of a permanent remedy for the MTHD/RHMW sites.   Identification  of sources of
contamination  and  possible  remediation of  the  ground-water plume will  be
addressed in a subsequent ROD.

     The  chosen  remedy  is  the most  cost-effective  solution,  is  expected to
attain ARARs,  is implementable  and technically  feasible,  and will  provide a
permanent solution  to the problem  of  potential  exposure of  MTHD residents to
contaminated ground water.
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                               RENORA, INC., SITE
                         EDISON TOWNSHIP, NEW JERSEY


HRS Score:  40.44                                                     NPL Rank: 378

Background

     The Renora, Inc., site, located in  Edison, New Jersey,  comprises  one  acre
of land in an area zoned  for  light industry.  A small commercial complex  is
adjacent to  the  site,  and a residential area,  containing a nursery school,  a
senior citizens'  center,  and an apartment complex,  lies  nearby.   All  ground
water from the site discharges into Mill Brook, which  borders  the  site.

     Between  1978  and  1982,  the  site  was  used by  Renora for  storage,   and
ultimately  disposal,  of  materials   containing  hazardous  substances.     An
inspection of the site by the  New Jersey Department of  Environmental Protection
(NJDEP) in 1978  detected minor  spills.  A subsequent  spill  prompted NJDEP and
the  Edison  Township  Department  of  Health  and Human  Resources   (DOH)  to
investigate the site,  resulting in an order to remove  all contaminated soil and
drums.  In 1980,  the NJDEP ordered Renora to cease all  operations  and  implement
remedial actions at the  site.   Although Renora and the NJDEP  agreed on  a  site
cleanup schedule shortly  thereafter,  Renora stopped cleanup activities  due  to
lack of funds.   Renora  abandoned the  site in June 1982 and  EPA included it  on
the NPL 6 months later.

     In 1984, EPA issued to all  known potentially responsible parties  (PRPs)  an
administrative order to cleanup  the site.  A  removal action, conducted by  PRPs
between October 1984 and April 1985, removed  liquid containerized  wastes,  PCB-
contaminated waste oil,  and visibly contaminated soils.  The  PRPs conducted a
remedial investigation/feasibility study (RI/FS)  of  the site between  May  1985
and May 1987  under  EPA oversight.  In support of the RI/FS,  EPA  conducted  an
endangerment  assessment  to  determine  risks  posed  by  the site.    Based  on
discussions following completion of the  FS, the PRPs appeared  to be willing  to
implement the selected remedy.   The ROD  was signed on  September 29, 1987.

Description of Site Work

     Results of the RI indicated that  the bulk of contamination at the site  is
in the soil.   Surficial soils (0-2 feet) contain PCBs, polyaromatic  hydrocarbons
(PAHs), and  to  a lesser  extent, volatile organic compounds (VOCs)  and heavy
metals.  Shallow ground water beneath  the site  is contaminated with low  levels
of the VOC chloroethane  and heavy metals.  Surface-water and  sediment samples
show  levels  of  heavy metals,  tetrachloroethane, and pesticides.    However,
contaminant levels in upstream and  downstream surface water and  sediment samples
were not significantly different.

     EPA's endangerment assessment revealed that the most significant  threat  to
human health is the  possibility  of  direct contact with contaminated  soils.
Trespassers,  on-site workers, and  future residents  of the property are  at the
highest level of risk.
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Description of Feasibility Study

     To address  site  contamination,  EPA evaluated  eight alternative remedial
action approaches on  the basis of effectiveness,  implementability,  cost,  and
compliance with other  CERCLA mandates.  EPA chose the following alternatives  for
evaluation:

          (1)  No action, with periodic ground-water monitoring;

          (2)  Capping   the    site,   with   periodic   ground-water
               monitoring;

          (3)  Excavation   of   PCB-contaminated   soils,   partial
               excavation  of  PAH-contaminated   soils,   off-site
               disposal,  and ground-water monitoring;

          (4)  Excavation  of  PCB-contaminated  soils  and off-site
               disposal,  partial excavation and biodegradation of PAH-
               contaminated soils,  and ground-water monitoring;

          (5)  Excavation  of  PCB-contaminated  soils  and off-site
               disposal,   and  excavation  and biodegradation  of P.AH-
               contaminated soils;

          (6)  Excavation of  PCB- and PAH-contaminated soils and off-
               site disposal,  slurry wall  installation,  and ground-
               water pumping and on-site treatment;

          (7)  Excavation  of  PCB-contaminated  soils  and off-site
               disposal,   excavation  and   biodegradation  of  PAH-
               contaminated soils,  and slurry wall  installation; and

          (8)  Excavation and  off-site disposal of all contaminated
               soils,  slurry  wall installation,  ground-water pumping,
               and on-site treatment.

     The  alternatives  were evaluated  according to  the  extent to which they
attain Federal  and  State applicable or  relevant and appropriate  requirements
(ARARs).   Remedial actions such as  excavation,  treatment,  and  disposal of waste
are subject  to a number  of  requirements under  the Resource  Conservation  and
Recovery Act  (RCRA).   Ground-water  contaminant levels  are regulated under  the
Safe Drinking  Water Act  (SDWA) and New Jersey Ground-water  Standards.   State
criteria,  advisories,   and guidance  governing  the soil contaminants, PCBs,  and
PAHs,   although not  strictly  ARARs,  were  utilized in  the  remedy selection
process.

     In choosing an appropriate remedy, EPA tried to maximize public and State
involvement.  "Public  acceptance"  and "State acceptance"  were  two criteria used
to evaluate each alternative.   EPA held a comment period in the fall of 1987  and
a  public  meeting on  September 1,  1987,  to address questions  concerning  the
remedial alternatives.
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Description of Selected Remedy

     After considering the eight alternatives,  EPA selected Alternative 5, which
involved   excavation  of  PCB-contaminated  soils,   biodegradation   of  PAH-
contaminated  soils,  and use  of ground  water  as an  irrigation medium  in the
bioremediation  system.   Excavation of  PCB-contaminated soils is  expected to
reduce PCBs to targeted treatment levels, providing  a permanent reduction in the
volume  of  contaminants   to   the  maximum  extent practicable.     Remaining
contaminants  will  be  subject  to  bioremediation,   which  is  considered  an
innovative  technology.    Implementation  of  the  bioremediation  system  will
significantly and permanently reduce  the toxicity,  volume, and mobility of the
remaining  contaminated  soil  at the site.   The selected remedy  is  expected to
attain ARARs.
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                       WALDICK AEROSPACE DEVICES SITE
                        SOURCE CONTROL OPERABLE UNIT
                          WALL TOWNSHIP, NEW JERSEY

HRS Score:  44.86                                                     NPL Rank:  271

Background

     The Waldick Aerospace Devices  site  is  an inactive  industrial facility
located in Wall  Township,  Monmouth County,  New Jersey,  60  miles northeast of
Philadelphia.  From 1979  to 1984, Waldick Aerospace Devices, Inc., manufactured
and plated metal components at the 1.75-acre site.   Based on a referral from a
former Waldick employee,  the New Jersey Department of Environmental Protection
(NJDEP),  the  Monmouth County  Division of  Criminal  Justice  (MCDCJ),  and the
Monmouth County  Board  of Health (MCBH) conducted  an  initial inspection of the
facility in June 1982.  This  inspection revealed  that Waldick was discharging
wastewater containing heavy metals,  organic  solvents,  and oil products directly
onto the ground around the main  manufacturing building.   In addition,  2,100
square feet of soils  at the rear of the plant appeared to  be  saturated with oil,
and 30 to 40 drums were scattered across  the site.

     In October 1982, NJDEP ordered Waldick  Aerospace to  clean up the site.  In
January 1983, under the supervision of NJDEP, the company  installed four on-site
monitoring wells.  Subsequent sampling in early 1983  indicated that soil and
ground water were contaminated with heavy metals and organic  compounds.  In June
1983, Waldick removed 80  cubic feet of  visibly  contaminated  soil  and  stored the
excavated material on a polyethylene membrane until it was disposed of off site
in 1984.

     In March  1984,   the  State prosecuted  Waldick  Aerospace and  its  sister
company,   KLS   Industries,  for  criminal   violation  of  Federal  and  State
environmental laws.  The court  ordered both corporations to pay all financial
obligations rendered and to  clean up the  site by September 1984.  In October
1984,  MCBH  inspectors  observed  that,  despite  the   removal  of the pile  of
excavated  material and  drums,  the  ground water  below  the  sit€>  had  become
contaminated with  cadmium  at levels  300  to 1,200 times  higher than National
Primary Drinking Water Standards.   MCBH  recommended additional downgradient
excavation and another round of  soil samples; to date, KLS has  neither responded
to MCBH requests nor taken further remedial actions.

     MCBH  identified and  notified five other  potentially responsible parties
(PRPs), but none has chosen to become involved in any remedial activities.  In
November 1985,  EPA initiated a remedial investigation/feasibility study (RI/FS)
to  identify source  control  remedial alternatives.    Off-site  migration  of
contaminants will  be  addressed in a future operable  unit.   The RI/FS for the
source control operable unit was completed in July 1987,  and the  ROD was signed
in September 1987.
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Description of Site Work

     The EPA lead RI revealed three distinct areas of contamination in the soils
along the  west,  south, and  east sides of the  buildings.   EPA designated  the
western areas  as Area  1,  and the southern  and eastern areas as  Area 2.   Area 1
was contaminated mainly with volatile  organic compounds (VOCs)  and petroleum
hydrocarbons  (PHCs); Area 2  contained high levels of cadmium and chromium,  as
well as VOCs and PHCs.  Contaminant pathways  for the  soil contaminants  include
overland flow, ground-water flow through an aquifer beneath  the site to a nearby
brook, and direct contact with soil.  The brook  is known to be contaminated with
a wide variety of  compounds, but the  RI could not determine the  extent  of  the
contaminated ground-water plume.

     Although  the  RI  examined  all  contaminated media,  only  the  soils  and
buildings  could  be  characterized sufficiently  to  proceed with  the FS.   EPA
decided to address  these  sources of on-site contamination  in a source  control
operable unit.

Description of Feasibility Study

     To mitigate contamination  of on-site  soil and buildings the  FS developed
the following  remedial  alternatives:

           (1)  No action;

           (2)  Improvement of site security,  and monitoring of ground
               water;

           (3)  Containment of contaminated soil with a slurry wall  and
               surface  cap;

           (4)  In  situ air  stripping of Area  1 and excavation  and
               vitrification of  Area  2;

           (5)  In  situ air  stripping of Area  1 and excavation  and
               incineration  of Area 2;

           (6)  In  situ  air  stripping  of Area  1  and excavation,
               removal, and  off-site  disposal  of Area 2; and

           (7)  In situ air stripping before excavation and removal of
               contaminated  soils  in Areas  1  and   2  for  off-site
               disposal.

     The applicable or relevant and appropriate requirements (ARARs)  identified
for the site include the  Coastal Zone Management Act  and Resource Conservation
and Recovery Act (RCRA) land disposal  restrictions.   Because neither Federal  or
State contaminant-specific ARARs for soils  have been established,  NJDEP  cleanup
objectives will be  utilized  as the  soil  standards for the site.
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     EPA held a public meeting in 1985, to present  the  RI/FS  work plan,  and in
1987, to present the results  of the RI/FS.  EPA also conducted numerous informal
meetings to inform the public of the site's history and its  current  status.

Description of Selected Remedy

     The  source  control  operable  unit  remedy  selected  for  the  site  (a
modification of Alternative  5) included the following  actions:

          •    In situ air stripping treatment of contaminated soils,
               and  excavation  and off-site disposal of all  treated
               soils with residual contamination above action levels;

          •    Appropriate   remediation   of  on-site   buildings   by
               decontamination or demolition;  and

          •    Installation  of  additional ground-water monitoring
               wells, environmental monitoring, site fencing, and well
               restrictions.

Ground water, surface water,  and stream sediments will be addressed in a future
operable unit, which will focus on  the off-site migration of  contaminants.

     The local community  is  in agreement with the  source control  action;  some
residents expressed concern about  their drinking water and whether the buildings
would be safe for occupancy  after decontamination.   EPA assured residents  that
ground-water investigations would continue, and that decontamination procedures
were expected to make the buildings safe  for  future use.
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                            WILLIAMS PROPERTY SITE
                         MIDDLE TOWNSHIP, NEW JERSEY

HRS Score: 40.45                                                      NPL Rank: 377

Background

     The Williams property site is located in Middle Township,  Cape May County,
New Jersey,  60 miles  southeast of Philadelphia.   The 5.6-acre tract  of wooded
land  contains  a well  and a  single residence  owned by  the  Williams  family.
Widespread dumping of refuse and  construction  debris has been  occurring at the
site for an unknown period of time.   In August 1979,  approximately 150 drums of
liquid chemical wastes and sludge were  emptied on the property adjacent to the
Williams residence.   In response,  the  New Jersey Department  of  Environmental
Protection   (NJDEP)  undertook  extensive  investigations  to  determine   the
environmental impact of the spill.  These investigations revealed that  surficial
sludge,  underlying  soil,  and ground  water  were  contaminated  with  organic
chemicals.

     During June 1980, NJDEP initiated  an  emergency cleanup of the  spill site,
removing  1,200  cubic  yards  of  sludge and  soil.    Subsequent domestic-water
monitoring revealed  little  or no evidence of contamination  until 1984,   when
contaminant levels in a well at the Williams site increased sharply. The county
health department subsequently closed the well. The residents  located near the
Williams property have been provided with municipal water, and the  private wells
at these homes are no longer in use.

     Two potentially responsible parties (PRPs) identified for the  site included
the property owner and the generator of the hazardous substances.   The property
owner is not  financially viable,  and NJDEP  could not reach an agreement with the
generator  to conduct  the remedial investigation/feasibility study  (RI/FS).
Through a cooperative agreement with the EPA,  NJDEP completed  an  RI/FS for the
site in July 1987.  The ROD for the  site was signed September  30,  1987.

Description of Site Work

     The State lead RI  revealed  a plume of organic contaminants  in the ground
water beneath the site.  The plume originated  from the area of the  1979 spill,
although the RI revealed  that  the 1979 spill was  not the only source  of plume
contaminants.  The plume extended 600 feet to  the northeast in the Holly Beach
Aquifer.  Because the ground-water plume was migrating  (at a rate of  90 to 200
feet per year), the concentration of contaminants was increasing at downgradient
wells and decreasing at upgradient wells.  The population threatened by exposure
to the  contaminated plume  included all  downgradient  private well  users   not
supplied with city water.  Downgradient homes  in the immediate vicinity of the
site had been connected to a municipal water supply.

     The top 2 feet of soil at the site also was found to be contaminated  with
phthalate,  tetrachloroethane,  and xylene at levels  exceeding  New Jersey  soil
cleanup criteria.   Populations at risk of exposure from  direct  contact with the
soil  included nearby  residents  and visitors.   The  RI  estimated  that   the
permanent population  within  1 mile  of the  site was  485,  with a peak summer
campground population of 4,738.


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Description of Feasibility Study

     Based on the results of the RI,  the State lead FS identified the following
remedial  response   objectives:   (1)  remediate  and  mitigate   migration  of
contaminated  ground water;  (2)  mitigate  leaching of  contaminated  soil into
ground  water;   and   (3)   prevent  direct  contact  with  contaminated  soil.
Technologies  were selected  and  screened  based on CERCLA criteria  and site-
specific conditions.  The  following  alternatives,  in  addition to a "no action"
alternative and institutional controls alternative, were developed and retained
for detailed analysis:

     (1)  Ground-water remedial alternatives:

          •    Extraction, air stripping,  and recharge;

          •    Extraction, carbon  adsorption,  and recharge;

          •    Extraction,  air  stripping,  carbon  adsorption,   and
               recharge;

          •    Extraction,   air   stripping,    carbon   adsorption,
               precipitation,   flocculation,    sedimentation,    and
               recharge;

          •    Extraction, air stripping, precipitation, flocculation,
               sedimentation, and  recharge;

          •    Extraction,    carbon    adsorption,    precipitation,
               flocculation, sedimentation,  and recharge; and

          •    Extraction,  air  stripping,  carbon  adsorption,   ion
               exchange, and recharge.

     (2)  Soil remedial alternatives:

          •    Excavation,  disposal  in off-site  permitted landfill,
               surface  grading, and  revegetation;

          •    Excavation,  disposal  in  on-site  landfill,  surface
               grading, and  revegetation;

          •    Installation  of  vacuum  extraction  well  and  soil
               vacuuming system;

          •    Excavation, off-site incineration, surface grading, and
               revegetation;

          •    Excavation, on-site incineration, surface grading, and
               revegetation; and

          •    In situ  destruction.
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     Federal  applicable  or  relevant  and  appropriate  requirements  (ARARs)
identified for the site included Resource  Conservation and  Recovery Act (RCRA)
air emission standards  and  Safe Drinking Water Act  (SDWA)  Maximum Contaminant
Levels (MCLs).   State ARARs included  ambient air quality  standards,  volatile
organic substance standards, air stripping permitting requirements, and ground-
water and soil treatment standards.

     In public  meetings held  concerning  RI/FS  results,  the local  community
expressed no strong positive or negative feelings  about  any of  the  remedial
alternatives,  but were  concerned  mainly about  the  time   required for  site
cleanup.   There was virtually no criticism of the  selected  remedy.

Description of Selected Remedy

     The remedy selected for the site  included the following activities:

          •    Ground-water extraction, treatment by  air stripping and
               carbon adsorption, and  discharge to the  aquifer;  and

          •    Soil   excavation and  off-site  incineration,   site
               restoration, and provision of an alternate water supply
               for the Williams residence.

This remedy  represented a  permanent solution for  the site  and  protects  human
health by  removing the  contaminants  from the ground water and removing  any
residual source of continuing contamination from the  site.   The remedy is  cost-
effective and is expected to attain ARARs.
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                       ENDICOTT VILLAGE WELL FIELD SITE
                    ALTERNATIVE WATER SUPPLY OPERABLE UNIT
                        VILLAGE OF ENDICOTT, NEW YORK

HRS Score: 35.57                                                      NPL Rank: 507

Background

     The Endicott Village Well  Field  is located in the Village of Endicott  in
Broome County, New  York.   The site consists of a well and associated ground-
water contamination.  The well field site  is  located near  industrial  tracts and
landfills  including Endicott landfill, which  was  identified  as  the probable
source of contamination.  No private homes are  located in  the  site area.

     The well  operated from  1950 to  the present,  drawing water  primarily  by
infiltration from the  nearby Susquehanna  River.  Currently, the well delivers
approximately  47 percent  of the total  water supply to the Endicott municipal
system.  In May 1981, following a chemical spill in Endicott, EPA sampled wells
and  detected  vinyl chloride  and  trace   amounts   of  other volatile  organic
contaminants  (VOCs)  in the well water.   The Public  Works Department for the
Village  of Endicott undertook  several  site  remediation  efforts,  including
installation of an aeration system and  a  purge  well to capture the contaminant
plume.  Despite the  remediation efforts, the Maximum Contaminant Level (MCL) for
vinyl chloride has been exceeded in ground-water discharge on several  occasions.

     Because of  the  threat  to drinking water supplies, EPA initiated remedial
actions  as  an  operable unit to provide safe drinking water to the  community.
The EPA lead remedial investigation/feasibility study  (RI/FS) for this operable
unit was completed  in  July  1987  and the ROD was signed September 25, 1987.  A
supplemental RI/FS for a second  operable unit has been initiated to evaluate the
nature  and  extent   of contamination,  to  evaluate  possible  source  control
measures, and  to further investigate source areas  and  companies that have been
identified  as  contributing  hazardous waste to  the Endicott landfill.   Notice
letters  will be  sent out to potentially  responsible  parties  (PRPs)  after the
supplemental RI/FS,   as appropriate.

Description of Site Work

     The primary objective of the RI for the first operable unit was to identify
the  source of  contamination to  the  well.   The  RI  indicated that  the most
probable source was  the landfill, particularly when inundated by the Susquehanna
River during floods.  The primary potential human health  impact at the site was
through  ingestion of contaminated ground  water.  Contaminants of concern were
determined  to  be various organic compounds.    Of  these  chemicals,  only vinyl
chloride was occasionally present at levels exceeding applicable or relevant and
appropriate requirements (ARARs) for the  site.

Description of Feasibility Study

     The objective of  the FS  for the first operable unit was to develop short-
term remedial alternatives capable of providing a safe drinking-water supply  to
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the  community.      Seven alternatives  were  developed and  evaluated  against
criteria mandated by CERCLA:

          (1)  No action;

          (2)  Installation of purge wells  only;

          (3)  On-site treatment of ground water via air stripping and
               discharge to the distribution system of the Village of
               Endicott;

          (4)  Alternative 3 with additional purge wells;

          (5)  Installation of a new Endicott supply well;

          (6)  Construction of a new treatment plant;  and

          (7)  Connections to the surrounding community supply.

     As mandated by CERCLA,  remedies must use permanent solutions and  treatment
technologies  to  the maximum extent practicable,  and  must also attain ARARs.
ARARs identified for the site include the MCL for vinyl chloride and  the  Federal
Water Quality Criteria for the other VOCs.  Other ARARs include  New York  State
guidelines  for  air emissions  from air  strippers,  and the  National Emission
Standard for Hazardous Air Pollutants (NESHAPS) for vinyl chloride.

     The remediation efforts conducted  at the site by community officials has
reduced the  level of public  concern over  the  contamination at the  well.   A
public meeting was held on August 11, 1987,  to discuss the  results of the RI/FS.

Description of Selected Remedy

     The  remedy  selected   for  the site   (Alternative  3)  consists  of  four
components:

          •    Treatment  of  the  ground  water,   by  means   of  air
               stripping,  and  subsequent  discharge of  the  treated
               water to  the distribution  system of  the  Village of
               Endicott for use as  drinking water;

          •    Continued operation  of the purge well by the Village;

          •    Continued monitoring for VOCs by the Village;  and

          •    Initiation of a  supplemental RI/FS with the New  York
               State Department of Environmental Conservation (NYSDEC)
               as lead agency.

The selected remedy is designed as  a short-term remedial  measure operable unit
and utilizes an alternative treatment technology to the maximum  extent  practi-
cable.  The  selected remedy is expected to be protective of human health  and the
environment, to be cost-effective,   and to attain all Federal  and State  ARARs.
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                               G.E. MOREAU SITE
                              MOREAU, NEW YORK

HRS Score: 58.21                                                       NPL Rank: 52

Background

     The GE Moreau site in Moreau, New York,  30 miles  north of Albany, was  used
as an industrial waste disposal site from 1958 to 1968.  An evaporative pit  at
the site  received approximately 452  tons  of waste material  generated by the
General Electric  (GE)  Company,  including  trichloroethylene (TCE),  PCBs, spent
solvents,  oils, sludges,  and other miscellaneous waste.  The  site was included
in  a  September  1980  Consent  Order  with the  New York  State  Department  of
Environmental Conservation (NYSDEC)  whereby GE would conduct  investigations  at
seven waste disposal sites in the  area and contain the waste materials at these
sites.

     In late 1982, it was determined that there were elevated levels of TCE  in
the ground water at  the site.   As  a result,  the  Town  of  Moreau installed
activated  carbon filter  systems  on  the  drinking water  systems of  70 homes
believed  to be  downgradient  from  the  site.    In  the summer  of  1983,  EPA
negotiated  with  GE  to address the  off-site contamination  problems.   These
negotiations resulted  in the signing  of  an Administrative Order  in November
1983,  under which GE agreed to:  1) install and maintain activated carbon filter
systems on homes whose well contamination exceeded specified  levels; 2) sample
and analyze  on a monthly basis drinking water  in homes downgradient from the
site on  a monthly  basis until full  remediation  is  completed;  3)  conduct  a
remedial investigation/feasibility study  (RI/FS);  4)  design and construct the
EPA-selected remedy; and  5)  conduct post-remediation monitoring and operation
and maintenance.   GE's  RI/FS  was completed in August 1985 and  the resulting ROD
was signed September 25,  1987.

Description of Site Work

     The RI  conducted  by GE  consisted of a complete  characterization of the
aquifer, including ground-water flow and contaminant transport phenomena.  The
RI indicated that a  contaminant plume  approximately  4,800 feet long and up  to
2,000 feet  wide  of  volatile  organic compounds  (VOCs)  emanated from the site.
The plume  originated at  the  GE Moreau  site  and  followed the  regional  ground-
water flow, extending  to surface-water  streams feeding  the New Reservoir.  TCE
was the most prevalent organic contaminant, found at levels up to 81 ppm.  The
RI also showed TCE and  dichloroethylene  contamination (up to 900 ppb)  in Reardon
Brook,  which feeds public water supply  reservoirs of a nearby town.   The  RI  also
identified 8,600 cubic  yards  of PCB-contaminated soils in the dirt roads  leading
to the GE Moreau site.

Description of Feasibility Study

     The primary purpose  of  the FS  was to identify remedies  that would ensure
a safe drinking water  supply for residents whose drinking  water wells had  been
adversely impacted by ground-water contamination emanating from the site. Other
objectives of  selected remedies would  include remediating  the water  quality  of
Reardon Brook and reducing the potential for  exposure  to PCB-contaminated soils


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adjacent  to  the  GE  Moreau  site.    Based on  these  objectives,  the  following
remedial alternatives were developed:

     (1)  Surface-water Supply:
          •    Activated  carbon  adsorption;  and
          •    Air stripping;

     (2)  Residential Water Supply:
          •    No action;
          •    Ground-water  monitoring only;
          •    Ground-water  pumping and recharge;
          •    Individual whole  house  treatment;  and
          •    Provision  of  an alternate water supply;

     (3)  Aquifer Restoration:
          •    Source   containment,  ground-water   monitoring,   air
               stripping, and discharge;  and
          •    Source  containment,  and  ground-water   pumping  and
               recharge;

     (4)  Soil Remediation:
          •    Excavation and on-site  soil disposal;
          *    Excavation and off-site soil disposal; and
          •    Surface sealing of soils.

     CERCLA requires  that selected remedies attain  applicable  or relevant and
appropriate requirements  (ARARs).  The ROD identified several Federal and State
requirements only as  "relevant and appropriate,"  including Safe Drinking Water
Act (SDWA) Maximum Contaminant Levels  (MCLs),  and New York State Ambient Water
Quality Standards and guidance values.

     EPA conducted numerous meetings with citizens groups and public officials.
The Town  Board of Moreau requested that EPA  require a new or  modified RI/FS
report,  on the  basis that  the   report  was inadequate  in three areas:   the
provision of alternative water sources;  the definition of the contaminated area;
and the restoration of the aquifer.  The town asserted that the plume emanating
from the site had migrated from the area defined as "contaminated" by the RI/FS.
EPA informed  the town that  the  contaminated areas had been  defined properly.
The Town of Moreau never shared any evidence of the alleged plume migration, and
EPA never revised  the mapping of the plume.   EPA  is completely satisfied with
the results of the RI/FS  report  prepared by GE and adopts it  as conclusive.

Description of Selected Remedy

     The selected remedy  for the site  included the following  actions:

          •    Treating Reardon  Brook  waters through air stripping;

          •    Providing  an  alternative water  supply for residences
               with potentially  contaminated drinking water wells;
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          •    Restoring  the  aquifer  through  source  containment,
               ground-water monitoring, air stripping, and discharge;;
               and

          •    Excavating PCS-contaminated  soil  and storing the soil
               onsite behind an existing slurry  wall.

     These  activities  are  expected  to  be  consistent  with  the  technical
requirements of both State and Federal  environmental laws, are cost-effective,
and provide adequate protection of public health, welfare, and the environment.
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                             HAVILAND COMPLEX SITE
                         TOWN OF HYDE PARK, NEW YORK

HRS Score: 33.62                                                      NPL Rank: 607

Background

     The Haviland Complex  site  is  located  in the  Town of  Hyde  Park  in Dutchess
County,  New  York.    The  275-acre  site  includes  an  apartment  complex,   an
elementary school, a shopping center,  and a number of private residences.   There
are residential and non-residential wells on the site whose water is  drawn from
an aquifer that underlies  the site.

     The Haviland Complex Apartments were constructed  in the 1960s, in proximity
to  an existing  shopping  center  and  local  residences.    The  shopping  center
contains a laundromat and dry cleaner, both of which have been in business since
the  1960s.    Complaints  about  the quality  of  ground  water  from  apartment
residents  began  in  October  1981.    Allegations   about  a  failure of the
laundromat's sewage disposal system were the  impetus for Dutchess County and the
New  York State  Department  of  Environmental  Conservation  (NYSDEC)  to   begin
testing the quality of the ground water  at  the.site.   These tests indicated that
the sewage systems of the  dry cleaner and  of a nearby car-washing business had
deteriorated  and  that  these systems were  at least  contributing to  the  site's
ground-water problems.

     NYSDEC  conducted  further  tests  in  1982  because  of  the  concern   about
potential contamination of ground  water with volatile organic  compounds  (VOCs)
from  the  laundromat's sewage  system.    As  a result  of  this  testing,  NYSDEC
recommended that  the City disconnect  its public water system  from a well near
the apartment complex,  and that the laundromat implement  a pretreatment system.
In  June  1985, NYSDEC  asked EPA  to perform  a  removal action to provide all
residents with potable water.  EPA declined to conduct a  removal action because
the   site   did  not  meet   the   necessary  criteria  (specifically,  because
contamination  levels at the site  did not  exceed  EPA's 10-day Health Advisory
levels for drinking water).  EPA listed the site on  the NPL in  October 1985 and
in  August  1986 began  a  remedial  investigation/feasibility study   (RI/FS)   of
source control options  and of providing an alternative water  supply.  The ROD
was signed September 30, 1987.

Description of Site Work

     The New York State lead RI  indicated  that the source  of contamination was
broader than the NYSDEC tests indicated, and appeared to  include several  septic
systems in  the area,  including those of businesses  connected  to the  Haviland
Shopping Center  (e.g.,  car wash and laundromat),  Haviland Complex Apartments,
and the Haviland Junior High School.  The primary  environmental exposure  routes
of chemical contamination  at  the site were drinking ground water and inhaling
VOCs while  showering.   Vinyl chloride  was  the  contaminant that presented the
highest potential risk to public health.
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Description of Feasibility Study

     The objective  of the FS  was  to evaluate  and  recommend a  cost-effective
remedial  action  that  would  minimize  the  risk  to  public  health  and  the
environment and  meet the statutory  requirements  of CERCLA.   Remedial  action
alternatives  were subjected  to a  preliminary screening based  on  technical
feasibility and  other criteria.   Of the  original  11 alternatives,  5  remained
after the screening:

          (1)  No action;

          (2)  Source control,  including  excavation of contaminated
               dry wells and septic disposal systems;

          (3)  Ground-water  extraction,  treatment,  and discharge  to
               surface waters;

          (4)  Ground-water  extraction,  treatment,  and discharge  to
               public water supply; and

          (5)  Provision of  public water  supply to all private well
               users  in the study area.

     The FS  also identified potential applicable  or relevant and  appropriate
requirements  (ARARS)  that the  remedial action must meet as mandated by CERCLA.
Federal ARARs included Maximum Contaminant Levels  (MCLs)  established under  the
Safe Drinking Water  Act  (SDWA),  ambient water quality standards set  under  the
Clean Water  Act  (CWA),  and  ground-water discharge  standards  set under  the
National Pollutant Discharge Elimination  System (NPDES) .   State ARARs included
New York Ground Water Standards and New York Surface Water Quality  Standards.

     The primary concern of residents expressed  throughout the RI/FS process  was
that a safe water supply be provided.  The public also was concerned about  the
possibility  that  exposure  to  VOCs  might  have  long-term  effects.   Some
individuals were extremely active in voicing their concerns by holding meetings
and attending Town Council sessions.   EPA held a public meeting on August  17,
1987, to discuss the  findings  of the RI/FS.

Description of Selected Remedy

     The remedy  selected for  the  Haviland Complex  site  was a combination  of
three  alternatives:     source  control  (Alternative  2),   aquifer   restoration
(Alternative 3),  and provision of an alternative water supply for area residents
(Alternative 5).   Specifically, ground-water extraction wells will  be placed on
site to contain  the  contaminant  plume,  and VOCs will be  extracted  from ground
water by means of a packed tower air stripper.  Residents also will  be connected
to the public water  service.

     The remedy  is expected  to meet all Federal and  State ARARs  within 5 to 10
years.  The remedy also is  cost effective, protective of human health and  the
environment because it reduces public exposure to contaminated ground water,  and
uses a combination of permanent and alternative treatment technologies  to  the
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maximum extent  practicable.  Residents  and the State of New York were  consulted
and concurred with the remedy  selected.
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                         KATONAH MUNICIPAL WELL SITE
                              BEDFORD, NEW YORK

HRS Score: 3535                                                      NPL Rank: 527

Background

     The Katonah Municipal Well site  is located in the Village of Katonah in the
Town of Bedford in Westchester County,  New York.   The well  itself is  located on
a peninsula that extends into the Muscoot  Reservoir,  a source  of  drinking water
for New York City. The well supplies  water to  the  residents of Katonah,  drawing
water primarily  from  the  reservoir, with  some  contribution from  an  aquifer
underlying the village.

     The  discovery of  contaminants  in a well supplying  the nearby  City of
Brewster prompted  the Westchester County  Department  of Health (WCDH) to  survey
a number of drinking water wells in the area in the fall  of 1978.   Samples taken
from the Katonah Well revealed  the presence of halogenated organics, including
tetrachloroethylene,  at levels exceeding New York  State  Department of  Health
standards for drinking  water.

     Several sources  of the contamination were identified.  The  New  York State
Department of Environmental  Conservation  (NYSDEC) traced the contamination to
the disposal facility of a waste hauler who had collected wastes  from the septic
systems of dry cleaners in the village  of Katonah.   Also, sampling  data later
confirmed claims  that Bedford town  employees  had dumped waste solvents  down a
drain located less  than 100 feet from the Katonah Well.

     The well was  closed  in December 1978 and the town developed an alternate
water supply by  installing another  well.    In  addition,  the  WCDH began  source
control measures.   Dry-cleaning establishments were required to pump out the
septic systems and modify their disposal  techniques.  Initial attempts  by the
Town and WCDH to remove contaminants  failed, however, and  the  site was referred
to NYSDEC for evaluation.

     Notice  letters were  sent  to  four dry-cleaning establishments and three
property owners identifying them as  potentially responsible parties  (PRPs).  A
special notice  letter,  concerning the solvent dumping  by town employees, was
sent to the Town of Bedford.  The site  was placed  on the NPL  in June  1986.  The
NYSDEC and EPA entered into an agreement in which EPA assumed  responsibility for
cleanup of  the contamination.   The remedial  investigation/feasibility study
(RI/FS) was completed in June  1987 and the ROD was signed September  25,  1987.

Description of Site Work

     Results of the EPA lead RI/FS indicated that  only tetrachloroethylene, the
original contaminant  of concern, appeared consistently in the sampling  data at
levels that  exceeded standards established for the  site.  Tetrachloroethylene
was  found in  levels  in  ground  water and soils  above  the New  York State
Department of Health and NYSDEC Technical and Operational Guidance  Series and
a Federal Water Quality Criteria Value for any single volatile organic compound.
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     The risk assessment  in  the  RI indicated that the primary potential  human
health risk was through ingestion  of contaminated ground water.   The  data from
the Katonah Well indicated that there was a  lifetime  excess  cancer  risk of
1CT5  associated with ingestion of  the  water from the Katonah Well.  The  only
potentially affected surface waters are the Katonah  Brook and nearby reservoir.
Sampling indicated that these bodies have not been affected by the contamination
and the potential for future  contamination is low.

Description of Feasibility Study

     The EPA lead FS identified and evaluated remedial alternatives for the site
with  respect  to  criteria in CERCLA and  the NCP.    Seven  alternatives  were
evaluated:

           (1)  No action;

           (2)  Excavation of  the soils and off-site disposal;

           (3)  Excavation of  the soils and off-site incineration;

           (4)  Extraction, treatment,  and  discharge of ground water
               to public  water  distribution system,  and containment
               of soils with  synthetic liner and clean cover material;

           (5)  Alternate water supply via relocation  of new  well;

           (6)  On-site treatment of ground water via air stripper, and
               discharge to public water drinking system;  and

           (7)  Renovation  of  existing  Katonah  Well  and   on-site
               treatment with air  stripper.

     Alternatives were evaluated in terms of practicability,  implementability,
and  cost-effectiveness,  and  for compliance  with the CERCLA requirement  that
remedies  attain  Federal  and  State  applicable  or  relevant  and  appropriate
requirements (ARARs) and utilize permanent solutions  and alternative  treatment
technologies to the maximum extent practicable.  ARARs at  the site  include the
Federal   Water   Quality   Criteria   of   10"6   excess   cancer  risk    for
tetrachloroethylene, and a State requirement concerning air  emissions from the
packed air stripper.

     Community  involvement  at  Katonah  was  limited.   Local  officials   have
received few complaints regarding the site since the well was shut down in  1978.
Public meeting attendance was limited to town officials and  one  PRP.  Specific
concerns  raised  during the  public comment  period  included  the physical  and
financial  impacts of  the  remedial  action on Katonah1s Commercial  Center,  the
relationship of Katonah Well  to the current municipal water  supply, and Federal,
State, and county jurisdictional issues.
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Description of Selected Remedy

     The selected remedy  for  the  site  is Alternative 6.   A new production well
and a ground-water treatment facility that employs air  stripping techniques will
be  installed at Katonah  Well.   A  water quality  monitoring program  will be
instituted,  and a  general  cleanup of  the  area  around the  pump  house was
recommended.

     The  alternative addresses  aquifer  restoration and  utilizes alternative
treatment technologies to the maximum extent practicable  to reduce  the toxicity,
mobility and volume  of contaminants.   It is expected to be protective of human
health and the environment, to be cost-effective, and  to attain all Federal and
State ARARs.
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                        SUFFERN VILLAGE WELL FIELD SITE
                              SUFFERN, NEW YORK


HRS Score:  35.57                                                      NPL Rank: 506

Background

     The Suffern Village  Well Field site  in the  Village of Suffern, Rockland
County, New York,   encompasses  30  acres   in  the  Ramapo  River Valley.   Four
production wells in the  well field provide water to approximately 12,000 people.
Recharge to the wells is derived mainly from induced infiltration of water from
the Ramapo  River.   The  Ramapo River is categorized  by the State  as a Class A
water body, best utilized for potable water supply.

     In September 1978, volatile organic compounds  (VOCs)  were  detected in tap
water collected from the municipal distribution system.   Subsequent monitoring
of the  site confirmed  that ground  water had become contaminated  with 1,1,1-
trichloroethane (TCEA) and trace amounts of other VOCs.  Three of the  four wells
were found to have  TCEA  at levels above New York Department of Health guidelines
and were shut  down.   A survey of local  industries  indicated that  the Tempcon
Corporation, a small oil burner  reconditioning  business,  had used TCEA prior to
the  contamination  discovery.   Tempcon subsequently  ceased using  a  seepage
disposal pit as well as TCEA-based cleaning products.

     In March   1979,  initial  remedial activities   were  conducted  under  the
guidance of the Rockland County  Health Department  (RCHD).   Waste materials were
removed  from  the   disposal  pit  and  contaminated  soil  was  excavated  and
devolatilized.   However,  these  initial remedial activities did not remove the
ground-water contamination.   Later  that year,  the Village constructed a spray
aeration treatment system to  remove  the TCEA from the municipal water supply.
The site was placed on  the NPL in October  1984.

     Since  Tempcon ceased disposal  activities,  the water quality of the wells
has gradually  improved.   Monitoring results in early 1985 indicated that the
aeration treatment was  no longer needed,  and two  wells were brought back into
service.    Since May 1985, the TCEA  concentrations  in  all four  wells  have
remained below State guidelines  with only  occasional  exceptions.  Nevertheless,
the complexity of the site hydrogeology led to the belief  that  even though the
suspected  source  had been  remediated,  slugs  of  contaminants may  have  been
released into  the  subsurface,  thereby causing the well  field  to be under the
continual threat of periodic contamination.

     EPA signed a  cooperative agreement with New York State in March 1985 to
undertake  the   remedial investigation/feasibility   study  (RI/FS).    Although
Tempcon  was  identified  as  a   potentially responsible  party,  it  did  not
participate in the RI.  The ROD was signed September  25,  1987.
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Description of Site Work

     The RI  was initiated  in April  1986  and included  soil and  ground-water
sampling programs.  TCEA and associated impurities were  detected in several of
the monitoring wells,  indicating  that  the supply wells still  contain ground
water with concentrations up to 30 ug/L TCEA.  At one  location,  concentrations
ranged  from  30  to  1,500  ug/L.   The only  pathway of  concern  identified  was
through ground-water migration from Tempcon and the area of high concentration.

Description of Feasibility Study

     After an initial  screening,  five  remaining remedial alternatives  were
considered:

           (1)  No action;

           (2)  Treat  the  water  supply  using  the   existing  spray
               aeration system;

           (3)  Treat the water  supply using a packed  tower aeration
               (PTA) system;

           (4)  Contain  the  plume,  treat  with  a  PTA  system,   and
               discharge to the river; and

           (5)  Divert the plume, treat with a PTA system, and pump to
               Suffern distribution  system.

The five alternatives were evaluated based on a number of criteria.   Applicable
or relevant  and  appropriate  requirements  (ARARs) identified  included the Safe
Drinking Water Act (SDWA) and  more  stringent State  guidelines.   However,  no
ARARs were predicted to be exceeded  at the well head.

     The local community's  initial concern about contamination  subsided after
a  newspaper   article  in  late  1978   reported that  contamination  levels  had
decreased  to a  safe  level.   One  public  meeting  was held  in  August  1987  to
present the  findings of the RI/FS.

Description of Selected Remedy

     A  "no action" alternative,  combined  with monitoring of  the ground water,
was  selected for  this  site.   Because natural  processes  will  contribute  to
reducing the toxicity and/or mobility of contaminants,  this decision meets the
CERCLA requirement of reducing volume, toxicity, and  mobility of contaminants.
In  addition,  although  there  is  a  statutory preference  for  treatment-based
remedies,  the  absence of  a  threat  to human health and the  environment in this
case renders treatment unnecessary.  Furthermore, ARARs  at  the  point, of ground
water are  not  now,  and  are not predicted  to  be,  exceeded.   In  addition,  this
alternative  is the most cost-effective solution.

     Because  toxic,  mobile  contaminants will  remain  in some locations in the
aquifer  for  5 years, the  selected remedy includes  restricting access  to  the
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aquifer.    If  monitoring  of  the  site  indicates   contamination  that  might
jeopardize public  health, a second operable  unit may be initiated to remediate
further problems.
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                             VOLNEY LANDFILL SITE
                     CONTAMINATION SOURCE OPERABLE UNIT
                               VOLNEY, NEW YORK


MRS Score:  32.89                                                     NPL Rank: 627

Background

     The Volney Landfill site, located  in Volney, New York, 25 miles  northwest
of Syracuse in Oswego County,  covers  85  acres and includes  an  inactive, unlined
landfill.    Land  in  the vicinity  of the  site  is  agricultural with a small
residential population.  Twenty-five single-family residences using individual
wells have  been  identified as potential receptors  of ground water  from the
landfill.   There  is a stream/wetland ecosystem downgradient from the  site.

     The landfill operated from 1969 to 1983 under the ownership of the Oswego
Valley Solid Refuse Board and, beginning  in 1975,  Oswego County.   Most of the
waste materials disposed of in the  landfill consisted of typical residential,
commercial, institutional, and light industrial waste.   During  1974 to 1975,
however, disposal of approximately  8,000  drums from  the  Pollution  Abatement
Services  (PAS)  site  was  permitted by  the  New  York  State  Department of
Environmental  Conservation  (NYSDEC).   Allegedly,  50 to  200 of  these drums
contained unidentified liquid waste, and their  condition  and location in the
landfill is unknown.

     In the mid-1970s, as the landfill  expanded, a leachate collection system
was installed  at  the site.    Collected  leachate from  the  site  was treated at
several locations between 1979 and 1986.  In March 1979, Oswego County and the
NYSDEC entered  into a  Consent Order  that  required the County to take a number
of corrective actions,  including  ground-water monitoring studies, evaluation of
leachate and sludge  treatment, and the development of a closure  plan.   Waste
disposal continued at the Volney Landfill until September 1983.  In the  fall of
1985, closure operations for  the landfill were completed by Oswego County.

     The site was separated into  two operable units because of the complexity
of the site conditions.  Through  a  cooperative agreement with EPA, the NYSDEC
completed  the  first  remedial   investigation/feasibility  study (RI/FS) for the
site in May 1987.  This RI/FS  addressed the  source  of  contamination in order to
prevent further potential contaminant migration from the site, and  to  eliminate
the threat of  direct contact.  The  ROD for this operable unit was signed  July
31, 1987.  A  subsequent operable unit  RI/FS  will  be  conducted to address the
contamination pathways.

Description of Site Work

     The RI conducted by NYSDEC  detected a variety of hazardous substances in
ground-water monitoring well samples, including 17 volatile compounds, 14 semi-
volatile compounds, and 10 metals.   Of  these  compounds,  eight were detected at
levels in  excess  of  either  Safe  Drinking Water Act (SDWA) Maximum Contaminant
Levels (MCLs) or  Clean Water  Act (CWA)  Water  Quality  Criteria (WQC).  Analysis
of surface-water samples  indicated a  generally lower incidence and concentration
of contaminants.  In addition, RI analyses performed on stream sediment  samples


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indicated  the  presence of fewer  hazardous  substances than  were  found in  the
ground-water   or   surface-water    samples,   although   at   somewhat  higher
concentration.

     The  primary  potential  human  health  impact  of  the   site  is  through
contamination  of  local ground water, which is  a  source  of drinking  water  for
private well users in the area.   No significant  violation  of drinking  water
standards has yet occurred.   Sampling conducted during the RI  indicated that  low
levels of surface-water contamination are not currently a threat to the wetland
and  stream environment.   However,  an  RI/FS  planned for  the  surface-water
contaminant pathway will provide more definitive  information.

Description of Feasibility Study

     The major objective of the  FS was  to evaluate  source control  remedial
responses that address the source  of contamination,  prevent further contaminant
migration  from the  site,  and  minimize the  threat to  human  health and  the
environment.   Technologies  found  to  be  compatible  with the  specific  site
conditions  and the  remedial  action objectives  for  the  operable  unit  were
combined into  source control  alternatives.   After  an initial screening,  the
following  eight  remedial  action  alternatives  were   subjected   to  detailed
evaluation:

           (1)  No action, with  site  monitoring;

           (2)  Excavation and off-site waste disposal;

           (3)  Supplementary capping of landfill  side  slopes;

           (4)  Slurry  wall  with  leachate  collection  and  off-site
               leachate treatment;

           (5)  Slurry  wall  with   leachate   collection  and   on-site
               leachate treatment;

           (6)  Supplemental  capping and  slurry wall  with  leachate
               collection and off-site leachate treatment;

           (7)  Supplemental  capping and  slurry wall  with  leachate
               collection and on-site leachate treatment;  and

           (8)  On-site incineration.

     Applicable or relevant  and appropriate requirements (ARARs)  considered in
the evaluation of these alternatives include Resource Conservation and Recovery
Act  (RCRA)  closure,  off-site transportation  and disposal,  tank  storage,
incineration, and technical landfill  cover requirements; Occupational Safety  and
Health Act (OSHA)  regulations;  and State pollution discharge  elimination system
permitting requirements.

     Throughout the Volney Landfill's history, community concern and involvement
have been high.  Four principal citizens groups have been  organized to address


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the community concerns  regarding the alleged disposal of PAS wastes at Volney
Landfill,  Fulton  Terminals,   and the  Clothier  Disposal  sites.    The  local
community is generally  in agreement  with the  proposed remedy.

Description of Selected Remedy

     The recommended  alternative for this  operable unit consists  of leachate
collection,  installation of a  slurry  wall, and  capping of the  landfill  side
slopes.   The combination  of capping  and leachate  collection  is  expected to
provide a significant reduction in the volume and mobility of hazardous wastes,
thus meeting CERCLA statutory preferences for permanence.  A recommendation for
leachate disposal was not made;  leachate will be treated either on site or off
site.  Both on-site and off-site  leachate treatment provide the same degree of
remediation and have similar costs.  A determination as to which option will be
selected will  be made  pending  the results of  the  treatability studies  to be
conducted during the remedial  design.
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                        VEGA ALTA PUBLIC SUPPLY WELLS
                  GROUND-WATER CONTAMINATION OPERABLE UNIT
                            VEGA ALTA, PUERTO RICO

MRS Score: 42.24                                                      NPL Rank: 334

Background

     The Vega Alta site consists  of a public water supply well field  located  in
the municipality  of  Vega  Alta,  approximately  32  kilometers  west of San Juan,
Puerto Rico.  Ground water is the primary  source of the public water  supply for
the area.  Major activities  in the area include agriculture and light  industrial
manufacturing which use chlorinated solvents.  The Vega Alta municipal landfill,
located within  part  of the  public  well field,  has been in operation since the
early 1970s and does not employ any leachate containment  systems.

     Contamination was first  discovered in June 1983 during  a survey conducted
by  the  U.S.  Geological Survey  (USGS).    Volatile organic  compounds   (VOCs),
including trichloroethylene,  were  detected  in  the well field, and 2 of the  10
wells  in the  field were  shut  down  by the  Puerto  Rico Aqueduct  and Sewer
Authority (PRASA).  The site  was placed on the NPL  in  September  1983.  Between
September 1983  and March 1984, the EPA Technical Assistance  Team sampled water
from the field.  Results indicated that the VOCs had not  migrated and had been
reduced  in  concentration.   An air  stripper constructed by PRASA operated from
September  1984  to   May  1985  at  the  Ponderosa  well,   the  site  of  initial
trichloroethylene contamination.

     The EPA lead remedial investigation/feasibility study (RI/FS) was initiated
in  1984.    The USGS  performed  some  of  the  sampling at the  site under   an
interagency  agreement  with  EPA.   The  FS  identified  alternatives  to  address
ground-water  contamination;   source control  actions will be  considered  in  a
subsequent operable unit FS.  Three potentially responsible parties (PRPs) were
identified from the  local  industrial plants and notice letters were  sent  in July
1984.   None  of the companies  indicated a  willingness  to  undertake  cleanup
action.  The ROD for the first operable unit was signed on September 29, 1987.
After the issuance of  the ROD, EPA sent notice letters to all PRPs giving them
the opportunity to implement  the remedy selected and participate in  the second
operable unit RI/FS to investigate and remedy the sources of contamination.

Description of Site Work

     The RI was performed  from April 1984 to March 1985, and the final RI report
was released in May  1986.  Results indicated that the contaminant plume had been
contained by  the  pumping  of the  well  field,  VOCs had decreased  over time, and
the contaminant plume decreased  by 58 percent in average concentration over the
16-month period.  Consequently, VOC levels in the distribution system  were below
action levels that would require a removal action.

     The  risk  assessment  at the  site  indicated  that   the  primary exposure
mechanism and health risk  is  by  ingestion  of contaminated ground water, which
poses a maximum total  carcinogenic risk of  1.5  x  10~A.  The  major contaminants
in   the   ground   water   are   VOCs,   particularly    trichloroethane   and
tetrachloroethane.  The primary surface discharge points for contaminated ground


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water  are  a  marsh  and  the  Atlantic  Ocean.    Consequently,  no   adverse
environmental effects are anticipated as a result of contamination released to
the environment.

Description of Feasibility Study

     The major objective  of FS was to  evaluate  remedial alternatives using  a
cost-effective approach consistent with the goals and objectives of CERCLA.  The
remedial response  will  address  the management of contaminated ground water as
the first  operable unit.   A detailed  analysis  of alternatives considered  the
following:

           (1)  No  action with monitoring;

           (2)  Ground-water  treatment with  discharge  to  the PRASA
               distribution system; and

           (3)  Ground-water treatment with surface-water discharge and
               provision of an alternate water supply.

     The alternatives were evaluated for compliance  with applicable or relevant
and appropriate requirements  (ARARs); reduction of toxicity, mobility or volume
of  contaminants;  short-term  and  long-term  effectiveness   and  permanence;
implementability;  cost; community and State acceptance;  and overall protection
of human health and the environment.

     ARARs for the ground-water cleanup included Safe Drinking Water Act (SDWA)
Maximum Contaminant  Levels  (MCLs),  Maximum Contaminant Level Goals  (MCLGs),
Ambient Water Quality Criteria (AWQC)  adjusted for drinking water, EPA Drinking
Water  Health Advisory,  EPA Reference  Doses,  Puerto  Rico Health Department
Administrative Order  10,  and a cumulative health risk of  1CT6.  Surface-water
ARARs included the National Pollution Discharge Elimination System (NPDES), AWQC
for aquatic  life,  and AWQC  for human health.   ARARs for air  releases  included
the Clean Air Act  (CAA).

     Meetings with citizens and local officials were held by EPA  to discuss  the
progress of the RI.  The public comment period on the FS  was extended following
a request by the  PRPs.   Comments on the FS included technical concerns regarding
the contaminants,  PRP and legal issues, and health  risks.

Description of Selected Remedy

     Alternative  2 was  the  initial selected remedy for  the site.   The  remedy
included ground-water treatment (by air  stripping and carbon adsorption)  at four
supply wells and  discharge  of  the treated water to  the distribution  system.
Treatment  would  bring the water to the  10~6 ingestion risk level to meet  all
ARARs.  Comments received from the Puerto Rico Department of Health,  PRASA,  and
the Water Pollution  Control  Committee of  Puerto Rico, however,  resulted in
modification  of  the  selected  remedy.   In  addition to  the treatment of four
public wells, two  private-well users will be provided an alternate water supply
from  the  distribution  system.   Also,  due  to  public  concern,  water from  the
Ponderosa well will not: be discharged  to the distribution  system but rather to
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surface water,  in  accordance with an existing NPDES  permit.   The alternative is
expected to  comply with ARARs and reduces the toxicity, mobility,  or volume of
contaminants.
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                            KANE AND LOMBARD SITE
                        SOURCE CONTROL OPERABLE UNIT
                             BALTIMORE, MARYLAND

HRS Score: 30.15                                                      NPL Rank: 724

Background

     The Kane  and Lombard site  covers 8.4 acres  of undeveloped  land in the
southeast quarter of Baltimore, Maryland.  The site is adjacent to a high school
and  is located  near  a  number  of  industrial,  commercial,   and residential
properties.  Between 1962 and 1971,  the site  was  excavated and refilled with
hazardous  and  solid waste;  surface dumping  of hazardous  waste  on  the site
continued from 1971 to 1984.   Several adjacent  properties  were also found  to be
excavated and may have been used for waste disposal.

     In 1980, Maryland inspectors  observed 400 to  500  drums  on the property,
many of which were damaged.  After negotiating with the site  owners, the  State
issued a Complaint in 1983 ordering the owners  to  clean  up the site.  The  State
was unsuccessful  in  forcing  compliance, however,  and in April 1984, requested
assistance from EPA.  EPA authorized the immediate removal of  over 1,000  drums
and 6  inches of  soil beneath the drums.   The  site was stabilized by regrading
and capping.

     In October  1984, the  site was  included  on  the  NPL.    EPA  initiated  a
remedial investigation/feasibility  study  (RI/FS)  in  October  1985,  and  a ROD
addressing source control was  signed September 30,  1987.   Adjacent properties
are being  investigated by the State of Maryland.   Because  these other  sites
contribute  to  ground-water  contamination,  complete  ground-water remediation
activities were deferred pending completion of  these other studies.

Description of Site Work

     The EPA lead RI of  ground-water and  soil sampling indicated  the presence
of  over   50  organic  compounds,    including   toluene,  PCBs,  ethylbenzene,
dichloroethane,  vinyl  chloride,  and polynuclear  aromatics.    The most likely
routes of  potential  human exposure to contaminants were  identified as use of
contaminated  ground  water   and  direct  contact   with   contaminated   soil.
Contaminants were detected in the upper two of three water-bearing zones beneath
the site.   Because residents  were  supplied with drinking water from the City of
Baltimore,  there was no immediate threat to the community.   However, the ground-
water contamination  threatened future use of the aquifers.  Although there was
a potential threat of direct  contact  due to the proximity of the high  school and
recreational facilities,  the clay cap constructed in 1984 reduced  that threat.

Description of Feasibility Study

     The objective of  the EPA lead FS  was to  identify alternatives that  would
eliminate or reduce  soil and ground-water contamination to  acceptable risk-based
levels.  Because the other  potential  hazardous waste  sites  in  the  area were
expected to  contribute to ground-water contamination,  the FS was limited to
consideration of  source  control  technologies  to reduce the problems resulting
from  the   Kane  and  Lombard  site.    Based  on  this  objective,  nine  remedial


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alternatives  were  identified,  of  which  the   following  passed  the  initial
screening:

           (1)  No action, with drainage-way maintenance and long-term
               monitoring;

           (2)  Construction  of subsurface containment  structures  to
               prevent ground-water  migration,  and  construction of a
               multi-layer cap;

           (3)  Excavation of all waste materials and on-site  or off-
               site incineration;

           (4)  Excavation   of   contaminated   fill   materials  and
               extraction (soil washing);  and

           (5)  In situ vitrification.

     Each  of  these  alternatives was  evaluated  with respect  to  effectiveness,
implementability, and cost,  and CERCLA requirements for permanent solutions,  use
of  treatment  technologies to  the  maximum extent practicable,  and  ability  to
attain applicable or  relevant and appropriate  requirements (ARARs).  The  ROD
indicated  that because  the  remedy selected would not address complete  ground-
water remediation, it would not attempt to ensure compliance with all ARARs  for
the entire site.   However, the ROD did not identify any of the ARARs that  would
be  pertinent  to  the entire  site.   Only  the  action-specific  ARARs  that  would
apply to the selected remedy were presented  (described  below).

     EPA held  a  public  comment  period from August  30,  1987  to September  28,
1987, and a public hearing was held on September 10,  1987.   The  primary  concern
expressed by the public was  the long-term health effects from  contaminants left
on  the site.

Description of Selected Remedy

     The remedy selected (Alternative 2)  involved:

          •    Removal of drums and  contaminated hot-spots  of soil;

          •    Construction  of subsurface containment  structures  to
               prevent ground-water migration;

          •    Construction of a multi-layer cap and drainage  system;
               and

          •    Continued ground-water monitoring.

The remedy  is  an interim measure  to control contamination from the Kane  and
Lombard site.  Ground-water contamination  from  other sources  will  be addressed
after investigations of  other  potential  sites  in the area are concluded.   The
remedy is  expected  to attain  action-specific  ARARs,  which included Resource
Conservation and Recovery Act  (RCRA) capping requirements; RCRA Land Disposal


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Restrictions; and Clean Water Act (CWA) requirements for discharges  to publicly-
owned  treatment works.   The selected  remedy was  discussed with  the State  of
Maryland and City  of Baltimore.
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                              PALMERTON ZINC SITE
                         BLUE MOUNTAIN OPERABLE UNIT
                           PALMERTON, PENNSYLVANIA


HRS Score:  42.93                                                     NPL Rank: 306

Background

     The Palmerton Zinc site, location of the New Jersey Zinc Company smelter,
is in the vicinity of Palmerton, Pennsylvania, approximately 70 miles north of
Philadelphia.   Smelting operations have  occurred since 1898  at  two separate
locations, the west smelter and the east smelter.  Until December 1980, primary
smelting of concentrated zinc sulfide ores caused emissions of huge quantities
of zinc,  lead,  cadmium,  and sulfur  dioxide that  led to  the  defoliation of
approximately  2,000  acres  on Blue Mountain,  which  is  adjacent  to  the  east
smelter.

     The Superfund investigation of the Palmerton  Zinc  site  focused on three
problem areas:   (1)  the deposition of heavy metals  throughout the valley  as a
result of air emissions from  the smelter;  (2) the slag pile, approximately 2.5
miles long, consisting  of  an estimated 33 million tons of smelting waste; and
(3)   the   defoliation  of  Blue   Mountain.      The   EPA   lead   remedial
investigation/feasibility study (RI/FS), completed in April 1987, focused on the
defoliated sections of Blue Mountain.  Under a Consent Order signed in September
1985, Gulf and Western, Inc.  and Horsehead Industries, Inc.,  past and current
owners of the  smelter,  are conducting RI/FSs for the other two problem  areas.
EPA  gave   these  potentially  responsible  parties notice  of  their  potential
liability for  the  implementation of the Blue Mountain operable  unit remedial
action.  The ROD for this  operable unit was signed September 4, 1987.

Description of Site Work

     The EPA lead RI  for the Blue Mountain operable  unit indicated that surface
soils at the site were  heavily  contaminated with cadmium (from a range  of 264
to 1,300  ppm) ,  lead  (1,200  to  6,475 ppm) ,  and  zinc  (13,000  to  35,000 ppm) .
Because  the  metals   were   bound in  organic  materials,   most of  the  metal
contamination was contained within the top 6 to 10  inches of soil.

     Water flowing across  the defoliated  portions of Blue Mountain has  eroded
the surface, become contaminated with metals contained in  the soil, and carried
the   metal-laden soil  into  a nearby creek.  Sampling performed  by Horsehead
Industries in March 1986,  under the consent agreement with EPA, indicated  that
the runoff exceeds EPA's ambient water quality criteria; in  some instances, the
levels  are  20   times   as  great.   The  environmental  impacts of  the  metal
contamination include defoliated vegetation; erosion; the absence of microflora,
lichens,  arthropods,  and  wildlife  species;  and  heavy metal  contamination of
fish.
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Description of Feasibility Study

     The RI/FS report,  completed  in April 1987, listed the following as  major
objectives of remedial  actions to be taken  at  the site:   (1) minimization  of
direct contact with contaminated  soil;  (2) reduction of the volume of  runoff;
(3) reduction of contamination in runoff; and  (4) mitigation of  environmental
damage.   Based  on  these  objectives,   source  control and  mitigation  control
technologies were developed and screened.  Technologies involving treatment were
eliminated in this initial screening due  to  their  high cost, poor performance,
unreliability,  or  non-implementability.    One  alternative,   collecting and
treating  runoff, was  deferred  for  further   study  in  a  subsequent  RI/FS.
Technologies retained for further analysis were the following:

           (1)  No action;

           (2)  Deed restrictions  only  -  prohibition of residential
               development and agricultural use  of defoliated portions
               of Blue Mountain; and

           (3)  Soil amendments and revegetation with deed restrictions
               - using  a mixture  of sewage sludge and  fly ash  to
               revegetate defoliated areas.

     Applicable or relevant and appropriate requirements  (ARARs) identified for
this site  included:   Clean Water Act  (CWA)  Best Management Practices  dealing
with  surface-water  discharges,  and   State of   Pennsylvania  Department  of
Environmental Resources  (DER)  "Interim  Guidelines  for  Sewage  Use  for  Land
Reclamation."  The DER  guidance includes guidelines for maximum  loading  rates
for metals, maximum dry sludge  application,  soil acidity adjustment, and  other
sludge application guidelines.

     The community  of Palmerton expressed concern about  the potential health
effects of the soil and ground-water contamination at the site, and also  about
the  financial  impact on the  zinc  company.    Many  of  their concerns  can  be
addressed only when further remedial action  for other operable  units is taken.

Description of Selected Remedy

     The selected remedy  for the site includes  using  sewage  sludge and  fly ash
cover to revegetate defoliated areas.   This  is an interim remedy that will  be
consistent with  the final comprehensive remedy for the site.  When the RI/FSs
for the other operable units are completed,  RODs will be issued to address all
aspects of the site.

     The ROD indicates  that  although  the remedy does not  attempt  to ensure
compliance with  all ARARs for  the  entire  site, it will be consistent, to the
extent  practicable,  with  those  action-specific  ARARs  addressing  sludge
application  and the  CWA Best  Management Practice  requirements.   The  rocky
terrain of Blue Mountain precludes compliance with some Pennsylvania DER sludge
application guidelines.
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                               PRESQUE ISLE SITE
                              ERIE, PENNSYLVANIA


HRS Score: 40.59                                                     NPL Rank: 376

Background

     The Presque Isle site is located  on the Presque  Isle  State  Park peninsula
within the  City  of Erie, Pennsylvania, and  includes  an abandoned natural  gas
well and its  surrounding contaminated area.   The  well,  known as  Presque  Isle
Beach No. 7  well,  intercepts  a  geologic  formation known  as  the  Bass  Island
Formation.   In 1982,  the well was  revealed to  be the source of  a  discharge  of
noxious,  hydrogen-bearing black  liquid that had been observed since  the early
1970s. The  Pennsylvania Department of Environmental Resources (DER) permanently
capped the  well  in  October  1982,  and determined at  that  time  that  previous
seepage did not  present any health hazards.   Presque Isle was included  on  the
NPL, however,  because of concerns  that the same  fluid  might be  seeping  from
other abandoned  gas wells, of similar  age and  construction,  in the area.

     Subsequent  investigations  revealed that  the  discharge released  hydrogen
sulfide  into  the atmosphere  and other hazardous  substances into  the  soil  and
shallow  ground water.   EPA and DER  investigations  of the source  discharge
focused on whether the discharge was a natural  phenomenon,  or if  it was related
to  the deep-well injection by  Hammermill  Paper  Company of approximately  1.1
billion gallons  of spent  pulping liquor into the Bass  Island Formation between
1964 and 1971.  Currently, Hammermill is the only waste generator that could be
linked to  the site  as  a potentially  responsible party (PRP).   However,  the
injection of pulping  wastes has  not been conclusively linked to the  discharge
at the Beach No.7 well.   Hammermill contends that the discharge was  a natural
fluid.  Even if  the fluid was identified as resulting  from  the pulping wastes,
Hammermill argues, it would be exempted from CERCLA because it was from a  State-
permitted disposal operation.

     The EPA lead remedial investigation/feasibility study (RI/FS) was completed
in October 1985,  and  the ROD for the site was  signed  September 30, 1987.

Description of Site Work

     Results from the EPA lead  RI  suggested that the chemical data  concerning
the initial source of the discharge is ambiguous,  and the resolution  of these
ambiguities at this time is impossible.  The most probable  conclusion of  the  RI
is that the injection program forced a possibly naturally  occurring  fluid near
the surface to seep from  the Beach No.7 well.

     Investigations determined  that the discharge at  the  well was an unusual
event, and that the threat to  the public was eliminated when access to the Bass
Island Formation from this well was permanently plugged  in  1982.   As  a result,
the only known source of the  seepage has been  capped.  Since that time,  there
have been no confirmed releases  of  hydrogen sulfide gas.  No  migration pathways
have been recognized,  and based on a July 1987  DER  sampling,  no significant
contamination is present at or adjacent to the Beach No. 7 well.
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Description of Feasibility Study

     According to  the EPA lead FS,  the  major  remedial  action objectives at the
Presque  Isle  site included:    (1) prevention/minimization of  direct  human
exposure  to  gaseous and liquid wastes from uncontrolled  discharges  and (2)
prevention/minimization  of potential contamination  of  surface and ground water
by pressure flow through fractures,  gas  and oil wells, or other pathways.  Based
upon these objectives and site-specific conditions,  the  following alternatives
were developed and evaluated:

           (1)  Depressurization of  Bass Island Formation;

           (2)  Installation  of  monitoring  wells   in  Bass  Island
               Formation to determine seepage origin;

           (3)  Installation  of  monitoring  wells   in  Bass  Island
               Formation to predict the potential migration pathway
               of  Hammermill's injected waste; and

           (4)  No  action;

The  ROD did  not  discuss  the  existence  of  any  applicable  or  relevant  and
appropriate  requirements  (ARARs)   for  the site,  nor  did  it  discuss  CERCLA
statutory preferences for permanent treatment-based remedies.

     Currently, there is only a moderate level of community awareness about the
Presque Isle site.   At a public meeting  held in August 1987 to discuss the RI/FS
and EPA1s  recommended alternative,  a local environmental group  representative
maintained that  the decision  was  premature, because studies  performed  may not
be  sufficient  to  ascertain the  extent  of hazard posed by  the  site now,  and
because a natural  phenomenon such as an earthquake  could cause another  seepage
incident.

Description of Selected Remedy

     Based on the  RI findings that  the site currently presents no threat to the
public  and that  no significant  contamination  is  present,  EPA selected "no
action" as  the remedy  for this  site.    The high cost  and great  difficulty of
performing the other remedial alternatives were also factors in this selection.
However, EPA and DER made a number of recommendations for activities outside the
scope of the ROD that Pennsylvania  State agencies should implement to minimize
further problems  or releases  associated with natural  formation brines  in the
area.
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                         SALTVILLE WASTE DISPOSAL SITE
                              SALTVILLE, VIRGINIA


MRS Score: 29.52                                                      NPL Rank: 737

Background

     The  Saltville  Waste  Disposal Site  is  located  in southwestern  Virginia
between  the  towns  of Saltville and Allison  Gap,  along  the  North Fork of the
Holston  River  (NFHR).    From  1951 to  1972,  the Olin Corporation operated  an
electrolytic  chlorine  and caustic  soda  plant  at  the  Saltville  site  that
manufactured chlorine gas and sodium hydroxide.  One  of  the  electrodes used  in
the chlorine-caustic process contained mercury  that was  solubilized  and  passed
into a waste pond  in the sludge and brine.   Additional mercury was lost  as  a
result of sloppy operating procedures.

     An investigation revealed the  presence of severe mercury contamination, and
both Virginia  and  Tennessee  banned fishing  in  the  NFHR.   Mercury losses  were
estimated by Olin to be  100 pounds per day between 1951 and 1970.   After  this
discovery, however,  Olin modified  its  procedures  to cut mercury  losses  to 1/4
pound per day.

     In  1970,  the  Virginia State  Water Control Board  (SWCB)  adopted a Total
Dissolved Solids Standard of 500 mg/1  for the river, which Olin was not able  to
meet.  As a  result  of  this,  as  well as increased operating  costs, Olin  closed
its Saltville operations in 1972.  Annual sampling  of fish and sediment  in the
NFHR since 1970 has  indicated mercury contamination  in the sediments and surface
water near the  site  and  in the  tissues of fish up  to 80 miles  downstream  from
the site.

     The  site  was  listed on the  proposed NPL  in December  1982,  and  the  SWCB
issued a Consent Order  to the  Olin  Corporation  that required  Olin  to  take
certain  remedial measures.   Under  the Consent  Order,   the  Olin Corporation
dredged  the  river bed,  extracted  mercury,  spread the sediments over the plant
site, and constructed a cap.  Additionally, Olin has continued fish and  sediment
sampling  to  monitor  the  extent  of mercury contamination.   The ROD  was  signed
June 30,  1987.

Description of Site  Work

     A remedial investigation (RI)  was not performed at this site because  of the
availability of data and ongoing sampling effort being conducted  by  Olin under
the  Consent  Order.    Instead,  a  risk  assessment  (RA)  was  conducted using
available data to  determine  if data  gaps  existed.   Several  data  gaps  were
identified in the RA.

     The  contaminant of  concern at the site is mercury seeping  into  the  NFHR
from the waste pond outfall.   Mercury accumulates in  fish and  other  organisms;
its effects  become  more widespread as  it  is carried up  the food chain.  The
NFHR, like other rivers  in the  area,  supports a relatively  diverse  population
of freshwater mollusks,  including  species of endangered mussels.
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Description of Feasibility Study

     The EPA  and the State of Virginia  initiated a feasibility study  (FS)  in
1986 and identified several remedial alternatives that would reduce the  mercury
concentration in the NFHR.   However,  due  to the inadequacy of data,  the Fish and
Wildlife Service and EPA  decided that a complete  bioassessment  of  potential
effects on the area's  environment  is necessary  to  develop remedial actions.
Thus, the  FS was used to develop  interim remedies only.

     Alternatives  identified in the FS were separated into two categories:  (1)
source  controls;  and  (2)  management  of  contaminant migration  in the  river.
After screening, four treatment alternatives were considered in  detail:

           (1)  No  action;

           (2)  Upgrading  run-on  controls  with ditches,  berms,  and
               downchutes;

           (3)  Upgrading run-on controls, treating pond  outfall, and
               installing  ground-water monitoring systems;  and

           (4)  Upgrading   run-on   controls,   capping   ponds,  arid
               installing  ground-water monitoring systems.

     Several  applicable or relevant and appropriate requirements  (ARARs) were
considered during the FS process:  Resource Conservation and Recovery Act (RCRA)
Subtitle  C,   Clean Water  Act  (CWA),  Virginia State  Water  Control  Laws  and
Regulations, Floodplains and Wetlands Executive Order and Guidance,  and Fish and
Wildlife Coordination Act  requirements.

     Despite the ban on fishing, community interest during the RI/FS process was
low  and no  public meeting  was  requested  during the  comment  period.    Most
comments on the  FS were received  from the States  of  Virginia and Tennessee and
from the Olin Corporation.

Description of Selected Remedy

     The selected  alternative  for  the Saltville site  consists  of upgradient
storm-water control  by  constructing ditches,  berms, and  downchutes;  treatment
of pond outfall; and ground-water monitoring  (Alternative 3).  The recommended
alternative  is an  interim measure  because  additional studies  are needed  to
determine  the extent of contamination.  These studies will include  a  ground-
water  study,  a  bioassessment,  and the  implementation  of additional sampling
along the NFHR.  Once these studies  are complete, a final remedial solution will
be developed.
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                        WEST VIRGINIA ORDNANCE WORKS
                              FIRST OPERABLE UNIT
                          MASON COUNTY, WEST VIRGINIA

MRS Score: 35.72                                                       NPL Rank: 89

Background

     The West Virginia Ordnance Works  (WVOW)  site  covers  8,323  acres  along the
east bank  of the Ohio River, 58 miles  northwest of Charleston.  One-third of
this area  is occupied by  the McClintic Wildlife Station, a  fish  and  migratory
waterfowl management area.  From 1942 to 1945, the site was used by  the Federal
government to produce trinitrotoluene (TNT) explosives.  Operations  ceased in
1945, and  the land was  deeded to  West Virginia on the condition  that the  site
be used for wildlife management.  Subsequent limited industrial  activity  at the
WVOW site may have contributed  to  the environmental  contamination.

     In May  1981, the West Virginia Department of Natural Resources  (DNR)  and
EPA identified the release of TNT processing wastes into a pond  in the wildlife
area.  Based on  subsequent studies by EPA and the DNR, WVOW was  placed  on the
NPL.   Hydrogeologic investigations  indicated the potential  for  migration of
contaminants  via surface-  or  ground-water pathways  to  deeper levels  of  the
aquifer  or  to  the  Ohio  River.     Nitro-aromatic   residues  and  other   TNT
manufacturing byproducts presented the most serious  carcinogenic  and  migratory
threat.   In  January 1986,  the  Department of Defense  (DOD)  and EPA agreed to
divide projected site work  into  two geographically  separate operable  units.
Remedial  efforts for  the first  operable  unit,  the TNT Manufacturing Area,
Burning Grounds, and Industrial Sewerlines, were  initiated,  as  additional  data
were gathered for the second operable unit.  The ROD for the first  operable  unit
was signed March 31, 1987.

Description of Site Work

     The remedial investigation (RI)  for the  first operable  unit  was  completed
in March  1986.    The RI  indicated  that the  major  sources  of nitro-aromatic
contamination were:   (1)  surface  and subsurface  soils  in the TNT and Burning
Grounds areas; and (2) the industrial sewerlines in the  TNT area.  Contaminants
in the TNT and Burning Ground areas  included  residual nitro-aromatic  compounds
and contaminated soils.    Nitro-aromatic compounds were  also  observed  in  the
ground water in the  shallow aquifer  and in surface  water in the  TNT area.
However,  no  nitro-aromatic compounds were detected in ground water from  supply
wells near the wildlife  station.  Residences will not be constructed  in the  area
nor will the ground water beneath  the site be used for drinking.

  The endangerment assessment concluded that although contaminants  presented the
threat of direct and indirect exposure,  the restrictive nature  of the wildlife
station reduced  the  actual  risk  to human  health.   Potential  risks  to human
health were  posed by consumption of contaminated  wildlife  at the site and by
reactive substances in sewerlines.
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Description of Feasibility Study

     The feasibility  study  (FS)  for the first  operable  unit was completed  in
October 1986.  The primary  objectives  were that the selected remedy  eliminate
the safety hazards of reactive wastes and stabilize the cancer risk  for hunters
and visitors  in  the  wildlife station.  For each  area to  be addressed  in  the
first  operable  unit,  a variety  of   remedial  alternatives  were  proposed,
including:     multimedia  capping,   off-site   and  on-site  incineration   of
contaminants, off-site and on-site landfilling, placement  of a soil cover,  and
no action.

     Use of any of the above technologies would require compliance with Federal
and State applicable  or relevant  and appropriate requirements (ARARs).   Federal
regulations that are potential ARARs included Resource Conservation and Recovery
Act  (RCRA)  disposal   requirements,  National  Ambient Air  Quality  Standards
(NAAQS),  transportation requirements, and Federal Water Quality Criteria (WQC).
State ARARs  included  water  quality  standards,  waste disposal regulations,  and
wetlands regulations.

     Members of  the  public  residing near  the  site have  shown interest  in  its
status since 1984,  primarily  because  of  contaminated ground water.    Public
meetings were held in February and  in  November 1986 to discuss the RI  and  the
FS, respectively.  The  fact  that oral  comments were in support of  the  remedy,
and that no  written  comments  were received at the November  meeting,  suggested
there was little objection to the chosen remedial  alternative.

Description of Selected Remedy

     EPA recommended  a four-part  remedial approach for the WVOW site:

          •    In situ flaming of reactive TNT residues in the Burning
               Grounds Area and installation of soil cover  over areas
               with high nitro-aromatics contamination;

          •    Installation of soil  cover  over contamination in  the
               TNT Manufacturing  Area;

          •    Disposal of asbestos  found in the Burning Grounds Area ;
               and

          •    Flushing  and backfilling of  reactive sewerline with
               installation   of   soil  cover   in   areas   of  high
               contamination.

     EPA found this  remedial  approach  to be the least costly alternative  that
also protects  against  direct  contact and  minimizes exposure pathways.   The
technologies  involved in the preferred remedy are  acceptable  and proven;  no
alternative offers a  significant  technical advantage.  The preferred remedy does
require long-term care to maintain the integrity  of the  soil cover.
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                        GOLD COAST OIL CORPORATION SITE
                                MIAMI, FLORIDA

HRS Score: 57.80                                                       NPL Rank: 67

Background

     The Gold Coast  Oil  Corporation  (GCO)  site  is  a 2-acre  parcel  of  land
located  in Miami, Florida.   The owner of the property,  CSX  Transportation,
leased it  to  GCO which, along with  Solvent  Extraction Incorporated, used  the
site as a solvent reclamation facility  during the 1970s.   The site  is within  a
commercial, industrial, and residential area having a population greater  than
80,000 within a 3-mile radius.   The  Biscayne  Aquifer,  which underlies a portion
of the site,  is the only ground-water source of drinking water  in southeastern
Florida.

     During facility operations,  the  companies sprayed residue directly onto the
ground and stored 53  drums  of sludge-contaminated soil on site.  There were  also
2,500 corroded and leaking  drums on  site containing sludge from the distilling
operation, contaminated soils, and paint sludges.  All wastes generated by  the
solvent recovery operations were disposed of or stored on  site.

     In  1980, the Dade  County  Department of Environmental Resource Management
(DERM) sampled the illegally dumped and stored wastes.  During  1981 and 1982,
the State,  DERM,  and  EPA sought to remedy conditions at the  site  through various
enforcement actions  against the facility,  its  operator,  and the   site owner.
When these  actions  failed,  EPA  initiated  an investigation  to  determine  if  a
CERCLA response  was  necessary.   In 1982,   in  response to  potential Federal
enforcement and  cleanup actions, CSX  evicted  GCO and agreed to clean up  the
surface  of  the  site  voluntarily.   Two major sampling efforts  were performed
after the  voluntary  cleanup, and it was  determined  that  the soil  and ground
water were still extremely  contaminated.

     EPA added the Gold Coast Oil site to the NPL in March 1983.   EPA identified
a number of potentially responsible  parties (PRPs).   In addition to  the cleanup
by CSX,  generators of waste stored  at the  site  joined together  to  perform  the
remedial investigation  (RI).  The RI was reviewed  by EPA and  the State, and EPA
followed with the feasibility study  (FS), completed in 1984.  EPA conducted an
endangerment  assessment in  late  1986, and  the ROD  for the site  was  signed
September  11, 1987.    Currently, negotiations  with  the  identified PRPs   for
performance of  the  selected remedial  action  are  ongoing.   A settlement is
expected by June 1988.

Description of Site Work

       The RI performed by the generators  in  1983  and additional studies by  EPA
and DERM indicated  that soil and ground water  were contaminated with organic
compounds and heavy  metals.  The studies  identified leaching of contaminants
from  surface  and subsurface  soils  to the  ground  water  and migration of
contaminated  ground water to surface water as the primary pathways  of concern.
The general contaminants of concern were halogenated  solvents,  non-halogenated
solvents, still bottoms from the recovery of these solvents,  and heavy metals.
Analysis of surface soil in 1983  indicated  that  the  distilling and drum storage


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areas were  contaminated with  chlorobenzene,  4-nitrophenol,  toluene,  and  di-
phthalate.  The  1986  sampling indicated residual  surface contamination.   The
1986 analysis of subsurface soil  samples revealed high levels  of toluene,  ethyl
benzene, xylene,  styrene, and bis(2-ethyl hexyl) phthalate, although levels were
lower  than in  1983.    Ground-water  data  indicated  an area  of  significant
trichloroethylene and tetrachloroethylene contamination in the northeast  corner
of the  site.   Concentrations  of metals in  ground water decreased between  the
1983 and 1986 samplings, but organics were  still present in 1986.

Description of Feasibility Study

     The  objective  of  the  FS was  to  identify  a remedy(ies)  that would  (1)
eliminate  the risk  of exposure from  contaminated  soils  and  (2) remediate
contaminated  drinking-water  sources  before  the  plume  migrated  further  and
contaminated  more of  the  Biscayne  Aquifer.    EPA  developed  and evaluated
technologies that addressed source control  and ground-water  contamination.  The
alternatives that passed the initial  screening were:

          (1)  No action;

          (2)  Air  stripping  of soils  and  ground-water  recovery,
               treatment,  and disposal;

          (3)  Steam stripping of soils and  ground-water  recovery,
               treatment,  and disposal;

          (4)  On-site  incineration   of   soils   and   ground-water
               recovery, treatment, and disposal;

          (5)  Stabilization/solidification of soils and ground-water
               recovery, treatment, and disposal;

          (6)  Off-site  incineration  of   soils  and   ground-water
               recovery, treatment, and disposal;  and

          (7)  Off-site disposal of soils and ground-water  recovery,
               treatment,  and disposal.

     Each  remedial  alternative  was   screened  against the  CERC1A criteria  of
effectiveness, implementability,  protectiveness,  and cost.    The  applicable  or
relevant and appropriate requirements  (ARARs) identified for  the  site  were  the
National Environmental Protection Act  (NEPA), Department of Transportation (DOT)
Hazardous  Material  Transport  Rules,  Resource  Conservation  and Recovery  Act
(RCRA)  land disposal ban,  Clean Air  Act   (CAA)  National Ambient Air Quality
Standards  (NAAQS),  Safe Drinking Water Act (SDWA) Maximum Contaminant  Levels
(MCLs), Clean Water Act (CWA)  pretreatment and discharge standards,  and Florida
Administrative Code Chapter 17-3 Water  Quality Standards.

     Although citizen interest in the Miami area in water quality is very high,
community involvement in the Gold Coast site was  limited.   EPA held one  public
meeting,  but  the majority of  those in attendance were  representatives  of  the
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PRPs.  EPA also published newsletters with current information on the site.  No
public comments were received during  the formal FS  comment  period.

Description of Selected Remedy

     The  remedial  action   alternative   recommended  for  the   site  included
excavation  of contaminated  soils with  off-site disposal  of hazardous  waste
sludges at an approved RCRA facility, and  stabilization/solidification of the
remaining  contaminated soils (Alternative  7) .    To address  the  contamination
found in  the  ground water beneath  the  site,  the recommended alternative also
included installation  of  a  recovery well field,  treatment  of recovered ground
water, and disposal of treatment residues.   EPA  has not yet selected the ground-
water treatment method.

     The chosen alternative  uses treatment technologies  to  the maximum extent
practicable, employs a permanent solution that reduces the toxicity and mobility
of the contamination,  and is protective of human health and the  environment.
EPA also expects the remedy  to  attain ARARs.
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                      NORTHWEST 58th STREET LANDFILL SITE
                     BISCAYNE AQUIFER FINAL OPERABLE UNIT
                             DADE COUNTY, FLORIDA


HRS Score: 49.43                                                      NPL Rank: 181

Background

     The Northwest (NW) 58th Street Landfill site is located  in northwest Dade
County, Florida.  From  1952  to  1982,  the  one-square mile site was operated as
an open dump.  Although it was  not  operated as a hazardous waste landfill, it
likely received  some  hazardous  waste.   Some early  wastes  were disposed of in
shallow trenches,  resulting in waste  deposits  in  the saturated  zone  of the
Biscayne Aquifer, which underlies the site.  The aquifer is the sole  source of
drinking water for the Miami/Dade County area.

     The site was placed on  the NPL in  1981,  and in October  1982, EPA ordered
the county to cease accepting municipal wastes.   The  site is one of  three NPL
sites that affect the  same  general area  of  the  Biscayne Aquifer.   The  other two
sites  are  Miami  .Drum Services  and  Miami  International Airport.   Because the
effects of these sites on the aquifer are interrelated, remedial  activities at
the  sites  are  being  addressed collectively.   EPA  completed  the  remedial
investigation/feasibility study (RI/FS) for the Biscayne Aquifer  study area in
1984.

     A total of  four  operable units will be completed as part of the complete
remedy under the Biscayne Aquifer Study. The  first  operable unit  involved soil
and ground-water cleanup at the Miami Drum Services site, and a ROD for source
control was signed in September 1982.  A ROD for the second operable  unit, the
Varsol spill  at  the  Miami Airport,  was signed in March  1985 and required no
action.   The ROD  for  the  third  operable  unit,  the  Study  Area Ground-Water
operable unit, was signed in September 1985 and called  for  air stripping in the
existing ground-water treatment process.    The final  operable  unit  addressed
source control at the  NW 58th Street Landfill and provision of  alternative water
supply.  The ROD  for  the landfill site  operable unit was signed  September 21,
1987.

Description of Site Work

     Numerous investigations have been conducted at the  landfill site,  including
the efforts conducted as part of the Biscayne Aquifer RI/FS.   Investigations at
this site concentrated on determining the magnitude and extent of ground-water
contamination resulting from the landfill.    A  study  by  the U.S.  Geological
Survey indicated the presence of a plume of contamination  migrating downgradient
from the  landfill.    The results  of the RI indicated that  widespread low to
moderate levels of several toxic contaminants, primarily VOCs, were present in
the ground water.

     An endangerment  assessment in  1986 found  eight contaminants  of concern in
the monitoring  wells  both upgradient  and  downgradient  of  the site:  arsenic,
chromium,     zinc,    benzene,    chlorobenzene,    1,1,2,2-tetrachloroethane,
trichloroethene, and vinyl  chloride. The primary route of human exposure to the


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contamination is through ingestion of contaminated water.  Of particular concern
are two  sets  of public  drinking  water supply well  fields located within  2.5
miles of the site.  The population served by the  well fields is estimated to be
about 750,000.

Description of Feasibility Study

     The FS for the landfill operable unit  focused on identifying remedies  to:
(1) reduce on-site soil  contamination;  (2)  reduce   site-related  ground-water
contamination;  and  (3) protect  downgradient  private  well  users.    The  FS
considered several alternatives applicable  to the landfill  site:

           (1)  No action;

           (2)  Installation of  on-site  recovery wells and  treatment
               of ground water prior to discharge;

           (3)  Installation  of   on-site  recovery   wells   and  deep
               injection well disposal  of recovered  ground  water;

           (4)  Containment of contaminants;

           (5)  Excavation of the  landfill;  and

           (6)  Implementation of  leachate control measures.

     Possible   remedies  were   screened   with   respect  to   practicability,
implementability, and  cost; CERCLA criteria for employing  permanent  solutions
and treatment  technologies  to the maximum  extent  practicable; and ability to
attain  applicable or  relevant  and appropriate  requirements  (ARARs).    ARARs
identified for the site include the Safe Drinking Water Act (SDWA),  Clean Water
Act (CWA),  Resource  Conservation and Recovery Act  (RCRA)  Subtitle D  landfill
closure requirements,  and Florida Administrative  Code (FAC)  requirements  for
resource  recovery  and  management,  permitting,  water  quality,  storm  water
discharge, and underground injection control.

     In July  1984,  a community relations plan was  completed  for  the  Biscayne
Aquifer  area.    Under  this  plan,  EPA  convened four public  meetings, held
workshops  on  issues   of special interest,  and  printed  and  distributed  a
newsletter.  Expressed  public interest  focused on closure  of the  landfill.

Description of Selected Remedy

     The selected alternative consisted of  closing the NW  58th Street  Landfill
in  accordance  with the technical  requirements  of  the   State  regulations,
providing municipal water to  private well users,  and  collecting  the water  and
treating it by air strippers  at municipal  treatment plants.   Closure activities
will  include  leachate control  through  a  combination  of  grading,   drainage
control, and capping.   Gas migration and odor  controls also will be implemented
as needed, as  will  long-term  monitoring of ground-water quality  and  operation
and maintenance of the  closure.
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     The  selected remedy will reduce  the amount of  leachate  produced and  its
mobility, but will  not  reduce  toxicity.   Alternatives involving treatment were
judged to be impracticable and not cost-effective due  to the magnitude of waste
to be treated (approximately 27  million cubic yards).  The remedy does provide
for long-term protection of  the  ground water and public health.  The remedy is
expected  to attain  ARARs.
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                       PARRAMORE SURPLUS COMPANY SITE
                             MT. PLEASANT, FLORIDA

MRS Score: 37.61                                                      NPL Rank: 455

Background

     The Parraraore  Surplus Company site  is  located in Mt.   Pleasant,  Florida,
approximately 30 miles from Tallahassee.   The  25-acre site is an active facility
which stores and resells surplus  government products.   The  population within  a
one-mile radius of  the site numbers less  than 100  and  the land adjacent  to the
site is used primarily for agriculture.

     In 1972, drums of paint residue, waste oil, alcohols,  and degreasers were
purchased  and  stored  on  the  site.     In 1982,  the  Florida  Department  of
Environmental Regulation  (FDER)  discovered that many  of  the 400 to  600 drums
were leaking contaminants,  thus  causing damage to the  site  vegetation.  EPA's
analysis of samples collected from the site indicated  PCB contamination  in the
soil.  The site was placed on the  NPL at  the  request of FDER.   In August 1982,
FDER notified the facility that  it was in violation of Florida Administrative
Code requirements concerning hazardous waste  storage facilities.  The owner of
the Parramore Surplus facility,  Mr. Houston  Parramore, was identified as the
primary potentially responsible party (PRP).   Following a meeting with FDER and
EPA, Parramore removed the leaking drums and contaminated soil  and shipped them
to  an approved  hazardous waste  disposal facility.   Parramore  also constructed
a fence around  the  site and posted warning signs.   In  July  of  1983,  additional
areas of contamination were discovered and Parramore was requested to excavate
and contain these areas.   In October 1983, FDER  conducted an inspection  of the
site and found  that all conditions of the site cleanup  had  been met.

      EPA conducted a modified remedial investigation (RI)  of the site in March
1985 and completed a public health evaluation  (PHE) in 1987 to determine whether
further soil remediation was necessary to protect human health.  No feasibility
study (FS) was  conducted because  results of the  PHE  indicated that  residual
levels of soil contamination posed no  substantial threat to  human health  or the
environment.   The ROD was signed  September 15, 1987.

Description of Site Work

     The  EPA lead  modified RI   included  soil  sampling  and  installation  of
temporary ground-water  monitoring well-points.    Results  of  the  modified RI
indicated the presence of soil contamination  on  site.   Results  of ground-water
samples were  considered inaccurate because  the ground water  contained large
amounts of suspended sediments.   The possibility of ground-water contamination,
however,  was considered  unlikely because  of  the  shallowness  of  the  soil
contamination and the limited area to which it was confined.

     The modified RI detected eight contaminants of concern  at  the site:  lead,
zinc,  cyanide, Bis(2-ethylhexyl)  phthalate, di-n-butyl  phthalate, ethylbenzene,
methyl ethyl ketone, and PCB-1254.  Those at  highest risk from exposure to on-
site contamination,  through inhalation or ingestion,  included Parramore Surplus
Company employees and  wildlife that feed on site vegetation.   The PHE,  which was
completed after  the  contaminated  soil was removed, detected lead, zinc, and PCB-


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1254 but at such low levels that they  did not  pose  a  threat to  human health or
the environment.  Based on the PHE,  therefore,  it was  concluded that no further
remediation of  the soil was necessary.

Description of Feasibility Study

     EPA did not complete  an FS of alternative remedial actions at the Parramore
site because  no need  for further remedial  action was  indicated by  the  PHE.
Applicable or relevant  and appropriate Federal and State requirements (ARARs)
included the  Toxic Substances Control Act  (TSCA),  Federal and  State drinking
water standards, and monitoring well installation and construction rules under
the Florida Administrative Code.

     EPA established an information repository  at a public library near the site
in July  1987  and published notices  of  the  proposed  remedial action plan and
requests for public comment.   The  public was also invited  to request a public
meeting with EPA to discuss the site and the remedial  action plan.  No comments
or requests for a public  meeting were  received and  no public  opposition to the
recommended action is expected.

Description of Selected Remedy

     No further remedial  action is  planned at  the Parramore Surplus Company
site.  A ground-water quality assessment will be conducted to ensure that local
drinking water supplies have not been adversely affected by hazardous substances
on site.   If  ground-water contaminant  levels exceed  standards  contained in
ARARs, a complete  ground-water investigation will be  done.
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                 TRI-CITY OIL CONSERVATIONIST CORPORATION SITE
                            TEMPLE TERRACE, FLORIDA


HRS Score: 3930                                                     NPL Rank: 408

Background

     The  Tri-City  Oil  Conservationist  Corporation site,  a  1/4 acre  property
located in Temple Terrace, Florida, 5 miles north of Tampa, was  used as a waste
oil collection and distribution center  from 1978  to  1983.  Operating conditions
during this time led to spills during transfer operations,  leaks from tanks and
liners, and accumulation  of  liquid wastes  at  the  site.   The  Florida Department
of Environmental Regulation  (FDER) received several public  complaints regarding
odor problems and "sloppy" practices.

     In  1982,  a  3,000 gallon waste oil  spill  occurred.    FDER  subsequently
analyzed  soil  and  sludge from the site and discovered hydrocarbons  and heavy
metals such as lead, chromium, and zinc.   Additional  sampling in 1984 revealed
high concentrations  of benzene,  toluene, xylene,  and  chlorinated  hydrocarbons
in soils as deep as 1 to 2 feet below the surface.   Contaminated soils posed an
environmental threat both to ground and  surface waters because of migration  from
the source area to potential water supplies.   Both human and  animal populations
use the  surface waters near the  site (such as the Hillsborough  River,  located
3,000  feet from the  site)  as  drinking water  supplies.  In  addition, eight
private drinking water  wells are  located within 1/4 mile of  the  site.

     Prior  to  the  remedial  investigation/feasibility  study  (RI/FS), both  EPA
and FDER conducted removal actions.  The ROD  for  the  site was signed September
11, 1987.   A potentially responsible party  search  report  identified  several
owner/operators and generators who were  potentially responsible  parties (PRPs).
One PRP, Tri-City Oil  Conservationist Corporation, was  dissolved involuntarily
on November 10, 1983,  and other owner/operator PRPs are  bankrupt.   EPA has  not
yet initiated a cost-recovery action against  the  PRPs  for  the $50,000 spent in
a removal  action  in  February 1984,  although  it may  do so  in the  future.    The
State of Florida currently is pursuing a civil cost-recovery  action against the
owner/operators  of  the  site  for the  $200,000  spent  for  its contamination
assessment and subsequent removal action.

Description of Site Work

     In  response to  the  substantial   endangerment  to  human  health  and   the
environment,  EPA  conducted  an immediate removal of  contaminated  waste oils,
sludges and contaminated  soils in 1984.   Because no follow-up sampling was  done
immediately after this  removal,  the  FDER assessed the remaining contamination
later  that year.   The assessment revealed that  VOCs and heavy metals still
contaminated the top 1  to 3  feet  of soil on the site.

     Based  on  this  assessment, FDER  initiated a removal  effort that  reduced
contamination to background levels.   This involved the removal of 850 cubic
yards  of  contaminated  soil,  removal   of two   above-ground   storage tanks,
excavation of a  16,000 gallon underground storage  tank, and removal of 5,000
gallons of organic liquids  and sludges.  When excavation was completed, clean


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fill was used  to bring the site back to  its  original grade.  This  action was
completed in May 1985.   FDER conducted follow-up ground-water  sampling in late
1985 and the first half of 1986.

     Upon review of the data generated by the FDER in its  sampling  efforts,  as
well as of other  data,  it  was  determined that the Tri-City  site no  longer was
contaminated.  All of the contaminated soil  and sludges have been removed to an
EPA-approved hazardous waste  facility,  and  1986  sampling  indicated that  no
ground-water contaminants exceeded drinking water standards.

Description of Feasibility Study

     The EPA lead RI/FS identified the following technologies for addressing the
site contamination:   thermal  destruction,  capping,  aeration,  solidification/
stabilization,  and surface soil/sediment  removal.   Applicable or relevant and
appropriate requirements (ARARs)  identified for the site included the following:
Florida  drinking and  surface-water  standards,  the  Safe   Drinking  Water  Act
(SDWA),  EPA  Ground-Water Protection Strategy, and the Clean Water  Act  (CWA).
However, because it appeared that the site no longer  posed a health-related or
environmental  threat,   an   evaluation   of   various    technologies   and   their
effectiveness,   applicability,   and  consistency  with  ARARs was  found  to  be
unnecessary.

     No extensive  community  relations activities have been conducted for the
site due to  the lack of interest expressed by the local community.  Both EPA and
FDER have received only  one  inquiry and no  complaints since the public  notice
outlining EPA's proposed plan for further activities  was issued in August 1987.

Description of Selected Remedy

     Under the  "no action" alternative selected  for  this  site, no  additional
remedial actions will  be performed.   Because all contaminated  soils have been
removed and  no  significant contamination reached ground-water  supplies  in the
area, additional remedial activities are not necessary.

     The ROD indicated that  the  remedy  selected was  considered to be the most
effective alternative in terms of removing the threats posed by the  site, given
both the clean-up  technologies available  and the size of  the  site.   Given the
small .volume  of  contaminated materials,  the  "no  action"  remedy  utilizes
permanent  treatment technologies  to  the  maximum extent  practicable.    EPA
concurred with the past remedial actions conducted by the State of Florida, and
the  State concurred with the  "no action" final remedy  chosen by EPA for the
site.
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                         TOWER CHEMICAL COMPANY SITE
                              CLERMONT, FLORIDA


MRS Score: 44.03                                                      NPL Rank: 286

Background

     The  Tower Chemical  Company site  is  located  15  miles west  of  Orlando,
Florida, along  the  eastern edge of  Lake County.  From 1957 to 1981,  the  Tower
Chemical Company manufactured,  formulated,  and stored pesticides at  the  site.
The  main  facility  included  a  burn/burial  area  for  solid  wastes  and   a
percolation/evaporation pond for acidic  wastewaters.  A  spray  irrigation field
consisted of four parallel  strips of land.

     Some  of  the chemicals manufactured at the  facility  required the use  of
dichlorobenzil  in  the  production process.    During  the  last few months of the
company's  operation, dichlorobenzil was manufactured in-house using  dichloro-
diphenyl-trichloroethane  (DDT).  Acidic wastewaters  from this manufacturing
process were discharged  into  the unlined percolation/evaporation pond located
at  the main  facility.    In  July  1980, the  pond  overflowed and  the   spray
irrigation field was then used  to discharge  acidic  wastewaters.

     As  a result  of  the  overflow, both  EPA  and  the  Florida  Department  of
Environmental  Regulation (FDER) initiated  studies  of the  Tower  site and the
nearby lake and stream.  All production was  stopped at  the  facility in December
1980, and  the facility was  subsequently  decommissioned.  The studies  indicated
high  concentrations of  DDT and  associated pesticide  compounds  in  the main
facility waste  disposal  areas,  stream,  and  ground  water.   Soils at  the  spray
irrigation field were contaminated by pesticides,  primarily within  the top foot
of  soil.

     The  Tower site  was  listed  on the NPL  in  December  1982.    A  remedial
investigation/feasibility study (RI/FS) was initiated in March  1984 and the ROD
was signed June 30,  1987.  Although several potentially responsible  parties were
identified, none have  made  a proposal  to undertake  any response actions.

Description of Site Work

     The EPA initiated the RI/FS after  it conducted an immediate removal measure
(IRM)  at  the  site.   During the IRM,  the  burn/burial area was excavated and
covered with a clay cap, and water  from the percolation/evaporation pond was
pumped, treated, and discharged.  The contaminated sediments from the  pond were
excavated, dewatered, and disposed off  site.  Although the FDER  conducted  an IRM
at  the spray irrigation field,  this area was addressed in  the RI/FS.

     The RI was conducted 8 months after  the IRM, and revealed that  only a  small
volume of soils (approximately 4,000 cubic feet) in the main facility area  still
exceeded the cleanup criteria.   The RI also showed that  no contamination existed
within the  spray irrigation field  in  excess of  the established soil cleanup
criteria  that  were jointly established for  the  site  by  EPA  and  FDER.   The
results of ground-water sampling and analysis at the main facility revealed that
the  surficial  aquifer, which  flows northeast  toward  the  unnamed creek, was


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contaminated with xylene,  ethyl benzene,  gamma-BHC, chlorobenzilate,  4,4'-DDT
with its derivatives,  and  several  other compounds.   Contaminant migration  had
extended  beyond  the  boundaries  of   the  burn/burial   area,  with   possible
contaminated  ground-water  discharge  occurring  into  the  ditch  east  of  the
facility.  Vertically,  contaminated ground water in the burn/burial  area  was
identified at a depth of 35 feet.

Description of Feasibility Study

     During the feasibility study (FS)  process, potential remedial technologies
were presented in groups  targeted  at  remediating a single  aspect of  the  site,
either  surface-  and   ground-water  contamination,  soil  contamination,   or
institutional controls.  These remedial  units then were combined to develop full
remedial alternatives  that  would be applied to the  conditions existing at  the
Tower  site.    After  screening,  eight  comprehensive  remedial  alternatives
remained, including the "no action" alternative.  The  other seven alternatives
included ground-water and surface-water monitoring  and various combinations of
the following:

          •    Municipal water  supply extension;
          •    Individual treatment units;
          •    Tanks and concrete pad removal;
          •    Point source runoff diversion;
          •    Capping;
          •    Surface regrading and revegetation;
          •    Surface soil/sediment removal;
          •    Ground-water removal;
          •    Excavation;
          •    Water treatment  technologies;
          •    Soil incineration; and
          •    Off-site disposal.

     Several  combinations  of  technologies  resulted in  remedial  actions  that
comply with applicable or relevant  and appropriate requirements (ARARs).   ARARs
considered in the FS  included the  Safe Drinking Water Act  (SDWA),  Clean  Water
Act  (CWA),  the  Resource Conservation  and Recovery  Act  (RCRA),  and  Florida
regulations for surface water,  drinking water, and  hazardous waste.

     Community interest in the Tower  site has  been limited,  although  area
residents did express concern about both health and non-health issues.   Findings
of the RI/FS were discussed at  the public meeting in October,  1986  that served
to initiate a 3-week public comment period.

Description of Selected Remedy

     The  alternative  recommended  for  the  Tower Chemical site  consisted  of
removal  and  treatment of  contaminated ground water;  provision of  individual
treatment units  for  two  private wells in the immediate  site vicinity;  removal
and thermal treatment  of contaminated  surface  soils from both  the overflow and
portions  of  the burn/burial  area of the  site;   pilot  excavation  of  the
burn/burial area to determine  the composition  of  the magnetic  anomaly;  removal
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of the two tanks,  concrete pads,  and contaminated soils;  and point source runoff
diversion.

     This  alternative  is the most  effective in terms  of removing the  threats
posed by the site and complies with  CERCLA.   This remedy  is  also cost-effective,
is  expected to  meet all  ARARs, and  uses  permanent solutions  and  treatment
technologies to the  maximum  extent  practicable.
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                           POWERSVILLE LANDFILL SITE
                             POWERSVILLE, GEORGIA


HRS Score:  35.53                                                      NPL Rank: 517


Background

     The Powersville Landfill site occupies  approximately 15 acres of rural land
in  Powersville,  Peach  County,   Georgia.     The   surrounding   land  is   used
predominantly for general  crop farming,  with some acreage devoted to  orchards
and cattle grazing.   The Providence aquifer, located beneath the site,  provides
water for irrigation and consumption.

     Originally used as  a borrow  pit, the  site began receiving municipal  and
industrial wastes  in 1969.   In 1973,  a portion of the landfill  was  formally
established  as  a  disposal  site  for  pesticides and  other  hazardous  wastes.
However, citizen complaints  and State investigations indicated  that pesticide
wastes were  also  discarded in  the municipal  section of the landfill  prior to
1973.  In March 1977,  the Georgia Department of Natural  Resources Environmental
Protection Division  (EPD)  recommended that t^e  site be closed because of  its
location above  the  Providence  aquifer.   The site was  included on  the NPL in
1983.

     EPA initiated  a remedial  investigation/feasibility  study  (RI/FS) of  the
site in December 1984.  In support of  the RI/FS,  EPA conducted  an  endangerment
assessment  to  evaluate  risks  to  public health.   Preliminary  investigations
revealed contamination in the soil and  ground water, both  of which  provide
potential pathways  for migration of  contaminants.   A draft  FS  for  remedial
alternatives was completed in July 1987, and the ROD was signed September  30,
1987.

Description of Site Work

     The RI  detected the presence of  chlorinated  organics and pesticides in both
soil and ground water.   Contaminants  of concern in ground water included benzene
hexachloride (BHC), vinyl chloride, lead, and 1,2-dichloroethane.  BHC  and 1,2-
dichloroethane  were  also found  to be  soluble in  the soil.   The  endangerment
assessment  indicated a  potential long-term  health  risk associated with  the
consumption of ground water from wells. Minimal  risk was found to be associated
with direct  contact with landfill surface soils by future residents of the  area.

Description of Feasibility Study

     EPA developed  a number  of remedial alternatives to address ground-water,
surface-water,  and soil contamination  at  the  site.   Alternatives were  screened
on  the  basis of  cost,  effectiveness, implementability, and compliance  with
applicable or  relevant and  appropriate  requirements (ARARs).   Preference  was
given to permanent solutions  and alternative  treatment  technologies.  After an
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initial screening, the following combinations of alternatives were  retained  for
further evaluation:

          (1)  No action, with  institutional controls on the use  of
               ground water and on the  site  itself;

          (2)  Capping  of the  hazardous  waste and  municipal  fill
               areas;

          (3)  Excavation and on-site  incineration of the hazardous
               waste area, and capping  of  the municipal  fill  area;

          (4)  Stabilization/solidification  of the  hazardous waste
               area, with capping of the municipal fill  area;

          (5)  Alternative 2 with ground-water pumping and treatment;

          (6)  Alternative 3 with ground-water pumping and treatment;

          (7)  Alternative 4 with ground-water pumping and treatment;

          (8)  Alternative 2 with provision of an alternative  drinking
               water supply;

          (9)  Alternative 3 with provision of an alternative  drinking
               water supply;

          (10) Alternative 4 with provision of an alternative  drinking
               water supply;

          (11) Alternative 5 with provision of an alternative  drinking
               water supply;

          (12) Alternative 9 with ground-water pumping and treatment;
               and

          (13) Alternative 7 with provision of an alternative  drinking
               water supply.

     ARARs identified in  the  FS  as  "applicable or relevant"  included the Safe
Drinking Water Act  (SDWA),  the  Resource Conservation and Recovery Act  (RCRA),
the Clean Air Act (CAA),  the Ground Water Protection Strategy,  and the Clean
Water Act (CWA).

     Community concern  regarding the  Powersville site  was  particularly high
while the landfill was  receiving waste  during the 1960s and  1970s.  Following
the discovery of ground-water contamination  in  1983, citizens began requesting
sampling of their wells,  and press coverage  of the site increased.  On August
4, 1987, EPA held a public meeting to discuss findings of the  RI/FS .  During  the
3-week comment period,  the major concern expressed by  residents was whether  the
quality of drinking water was sufficiently high.
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Description of Selected Remedy

     The remedial  action  alternative  recommended for the Powersville  Landfill
is Alternative  8,  capping  the hazardous  waste and  municipal landfill  areas
coupled with provision of an alternative drinking water  supply.   Institutional
controls will be established to prohibit drilling of  wells  in  the  area.

     The caps will be designed to minimize  flow of liquids through the  landfill
over the long term  and should reduce or eliminate the mobility of  contaminants
in both  disposal  areas.   The alternative  drinking  water  supply system  will
provide a  reliable, long-term source  of drinking water to nearby  residents.
Although   adding   a new   drinking  water   system  will  not  alleviate   site
contamination,  it will reduce  long-term health  risks.   The  remedy  is  cost-
effective,  uses  permanent  treatment  technologies  to  the  maximum  extent
practicable, will protect public  health,  and is expected  to meet ARARs.   Capping
and  installation of an  alternative water  supply system  are  both  relatively
simple and established technologies.

     The State of Georgia has concurred with EPA's selection of the recommended
alternative.  Because the site was operated by a county of the  State,  the State
must  pay   50  percent of  remedial  costs.   If a more   costly alternative  is
ultimately  chosen,  the  State  may disapprove all  or  some portions  of  the
approach.
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                              NEWPORT DUMP SITE
                               WILDER, KENTUCKY


HRS Score: 37.63                                                      NPL Rank: 453


Background

     The Newport Dump  site  is a former municipal landfill located in the  City
of Wilder  (population 633),  about  three miles south  of  Newport,  a suburb  of
Cincinnati, Ohio.  The 39-acre site is bounded on the north and east  by  a small
industrial park and on the  west by the Licking River, a  tributary of the  Ohio
River.  About 250 feet downstream of  the  site  is  the main raw  water  intake for
the Kenton County Taylor Mill water treatment  plant, which serves about 75,000
consumers in the nearby counties.  A stream on the south of the landfill drains
to the Licking River.

     The site was used by  the City of Newport for disposal of residential and
commercial wastes from the  late 1940s until its closure  in 1979.  During  this
time, the City was cited for numerous  permit violations including open burning,
absence of daily cover, on-site ponding of water,  uncovered refuse, presence  of
leachate,   and  handling hazardous  waste without  a permit.   The landfill was
closed  in  1979  but   the  final  closure  plan was  never  fully implemented.
Ownership was transferred  to  the Northern Kentucky Port  Authority (NKPA)  with
the understanding that the NKPA would remediate the  site.

     NKPA activities  included partial construction of collection trenches and
landfill slopes.   Although the  NKPA  made  these  initial  remedial  efforts,  it
lacked adequate funding to  implement the  agreed order with the State of Kentucky
for  closure.    Subsequent   site   inspections  indicated leachate  breakouts
containing lead, chromium, and PCBs,  seeping into  the  Licking  River.  In 1984,
the EPA placed the site on the NPL.  A draft remedial  investigation/feasibility
study (RI/FS) was submitted in November  1986,  and  the  ROD was  signed March 27,
1987.

Description of Site Work

     EPA initiated the RI investigation  in 1985 and  completed  it in  1986.  The
major concern at the site was  that leachate would migrate into the Licking River
and  the unnamed stream to  the south and enter the  raw  water  intake  located
across the Licking River.   The RI assessed the nature and extent of on-site and
off-site contamination, and evaluated exposure hazards to human health  and the
environment  in  the  area surrounding  the Newport Site.   Specifically,  the  RI
assessed  the levels  and  pathways of  ground-water  contaminants,   determined
contaminant  levels in  the  Licking  River and the unnamed  stream  and  in  surface
and subsurface soils,  and evaluated the effect of leachate on aquatic  organisms.

     Results of the chemical  analysis indicated that contaminant levels in the
surface soils, surface water,  and  sediment downstream all were  below accepted
health criteria.  However,  the shallow on-site ground water,  both immediately
below the  waste and  at the  banks  of the Licking River  and  unnamed  stream,
contained above health base levels of some heavy metals and organics.


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Description of Feasibility Study

     The purpose of the FS,  completed in late 1986,  was  to identify remedies to
mitigate contamination at the  dump  site in order to remove potential  risks to
human  health  and  the  environment.    Consideration of  the  remedial  action
alternatives took into account the  CERCLA provisions that permanent  solutions
and treatment technologies be chosen to  the maximum extent practicable, and that
the remedy attain applicable or relevant and appropriate  requirements  (ARARs).
The major  ARARs considered  were the  Resource Conservation  and Recovery  Act
(RCRA)  requirements  for  ground-water cleanup,   the  Floodplain Management
Executive Order, the Clean Water Act (CWA), the Occupational  Safety and Health
Act (OSHA), and EPA's Ground-water  Protection  Strategy.

     In addition to  "no  action"  and "no action with monitoring"  alternatives,
four remedial action alternatives were  evaluated:

          (1)  Multi-media monitoring, leachate collection, regradirig,
               and revegetation;

          (2)  RCRA  capping  the  entire site, repairing the leachate
               collection system, and installing a gas collection aind
               treatment system;

          (3)  Extensive excavation and solidification/stabilization
               that  would  require   separation  of  waste material,
               backfilling,   and regrading; and

          (4)  Excavation, disposal of waste in an off-site landfill,
               backfilling,   regrading,  and revegetation.

     At a public meeting held  in Newport during March 1987 the  general concern
was  whether  had  EPA  successfully  determined   the   nature  and extent  of
contamination and had considered practical alternatives to remedy the  site.

Description of Selected Remedy

     The  selected   alternative action  (Alternative  1)  required  monitoring,
leachate collection, regrading, and  revegetation --  specifically,  ground-water,
surface-water and gas monitoring  using monitoring wells  and  sampling  uptakes,
repair and  replacement  of the existing leachate  collection  system to prevent
migration of  leachate,  and  regrading of  the  landfill  bank to  prevent further
erosion.  The cost for this  remedy  was  approximately one  million dollars.

     This alternative is  cost-effective and protective,  is expected  to attain
ARARs,  and uses  treatment   technologies  to  the  maximum extent  practicable.
Although  this  remedy does not include  permanent  treatment,   it was considered
economically viable  and  technically adequate due to the  minimal  contamination
found in surface soil and ground-water  discharge.
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                                 SODYECO SITE
                          CHARLOTTE, NORTH CAROLINA

HRS Score: 51.93                                                      NPL Rank: 151

Background

     The  Sodyeco  site  is  located  on  the  Catawba  River,  10 miles  west  of
Charlotte, North Carolina.  Approximately  20  to 30 people  live within  1/4  mile
of the  site.   Surface  drainage  from  the west  side of the  site is  directly
discharged into the Catawba River.  The 1,300-acre site contains  an operational
manufacturing facility consisting of production units and a wastewater treatment
facility,   which are  currently owned  by  Sandoz  Chemicals Corporation.   The
manufacturing facility  began producing  liquid sulfur dyes in 1936  under the
ownership  of Southern Dyestuff  Company (Sodyeco) but  now produces specialty
chemical products  for the  agrochemical,  electronic, explosive,  lithographic,
pigment, plastic, rubber,  and general chemical industries.  Waste materials  were
disposed of  in on-site landfills,  storage  pits, and  settling  ponds.

     In September 1980,  organic solvents  were  detected in the facility's potable
water well and  in adjacent water  supply wells.   Residents of five  homes  were
evacuated, and  the facility water supply source was changed  from ground water
to the Catawba River.  Results of a site investigation conducted by EPA in  June
1982 revealed the presence of volatile organic contaminants (VOCs) in the ground
water and surface water on the site.  The site was placed on the NPL in  December
1982 because of its proximity to  potable  water wells and the presence of two
municipal water intakes on  the Catawba River.

     EPA and Sandoz  signed a remedial investigation/feasibility  study (RI/FS)
consent agreement  in February 1986.   Because  of the agreement, no potentially
responsible  party  (PRP) search was necessary.  The final RI report and a draft
FS report were  prepared by Sandoz under the  consent agreement and released  to
the public in August  1987.  The ROD  was  signed September 24,  1987.

Description of Site Work

     The RI  included soil,  sediment, surface-water,  and ground-water  sampling
at  five different areas  identified as sources  of contamination.   Results
indicated  that  some  portion of  both  the upper  and lower aquifers had  been
contaminated with  VOCs.   As a result of volatilization and dilution,  however,
this contamination did not  appear  to have  affected the Catawba River.  Because
the aquifers are not used for drinking water, potential risks to human health
from exposure to  on-site organic  contaminants via inhalation, ingestion, and
dermal  contact  are  low under present use  conditions  at the  site.    There  is
potential for increased human health risks, however, if the ground water becomes
a source of  drinking water.

Description of Feasibility Study

     The purpose   of  the  FS  conducted  by Sandoz  was to  identify actions  to
mitigate contamination in soil and ground  water and  to reduce risks  to human
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health and  the environment.   Remedial alternatives  under consideration  that
passed initial screening were:

     (1)   No action; ground-water monitoring only;

     (2)   Ground-water recovery and treatment;

     (3)   Capping, soil excavation and incineration, and ground-water
          recovery and treatment;

     (4)   Capping, soil excavation and thermal stripping, and ground-
          water recovery and treatment;

     (5)   Capping,   innovative   soil   treatment,   excavation,   and
          incineration, and ground-water recovery and  treatment; and

     (6)   Capping, natural  flushing,  excavation,  and  incineration,
          and ground-water recovery and treatment.

  Federal applicable  or relevant  and appropriate  requirements  (ARARs) under
consideration included Maximum Contaminant Levels (MCLs) and MCL goals  (MCLGs)
under the Safe Drinking Water Act (SDWA); Water Quality Criteria (WQC)  under the
Clean Water Act (CWA);  National Ambient Air Quality  Standards  (NAAQS)  under the
Clean Air Act  (CAA); permitting  and incineration standards under the Resource
Conservation  and  Recovery  Act (RCRA);  Hazardous  Materials Transportation  Act
(HMTA) standards; Occupational Safety and Health  (OSHA) planning requirements;
National  Pollutant Discharge  and  Elimination  System (NPDES)  standards   for
treated  ground water;  and  North  Carolina  MCLs  adopted  from  Federal  SDWA
standards.

     During public meetings citizens expressed a desire for remedial  action at
the  site.   No  public opposition  is  expected  if  the  remedial alternative
recommended below is implemented.

Description of Selected Remedy

     The remedy recommended for the Sodyeco site  included extraction, treatment,
and  discharge  of   ground water;   possible  soil  excavation  and  off-site
incineration; capping;  and on-site treatment  of  contaminated soils  left  on  site
(Alternative  5).  The  innovative soil treatment technologies to be considered
are  flushing,  soil  washing,  thermal processing,  and  in situ steam stripping.
This recommended  remedy permanently and significantly reduces  the volume  and
mobility of contaminants in the soil and is expected  to meet Federal  and State
ARARs.  Long-term operation and maintenance of  the asphalt cap and  long-term
ground-water  monitoring will  be  required  to  ensure the  effectiveness   and
permanence of the remedy.
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                             GEIGER (C&M OIL) SITE
                      CHARLESTON COUNTY, SOUTH CAROLINA


HRS Score: 3225                                                      NPL Rank: 640

Background

     The Geiger  (C&M  Oil)  site  is located  in central Charleston County,  about
10 miles west  of the  City of Charleston, South  Carolina.   The 5-acre site  is
located  in  a  sparsely  populated rural  area  that  includes environmentally
sensitive  wetlands  that are  a  critical habitat  for several Federally-listed
endangered  and  threatened  species.    The   site,  which  was   formerly  used  to
incinerate waste  oil,  includes  eight  unlined lagoons constructed between 1969
and 1971 to hold waste oil prior  to recycling and incineration.

     In late  1971,  in response  to complaints from  area residents,  the  South
Carolina Pollution Control Authority  (SCPCA) ordered that  all incineration and
waste disposal activities be stopped.   After several serious  oil  spills in 1971
and 1974,  the  Charleston County Health Department closed the site and C&M Oil
Distributors,  Inc., purchased all reclaimable oil  at  the  site.   In 1982, the
site was purchased by  George Geiger, who filled in the lagoons with soil so that
the site could be used to store equipment for his pile driving company.

     The  EPA,  with  aid  from  the  South  Carolina   Department  of  Health and
Environmental  Control,  initially  investigated the site in February 1980.  The
waste oil was found to contain volatile organic compounds (VOCs), heavy metals,
and PCBs.   Although  samples  from two private wells upgradient  from the  site
indicated  no  contamination,  the  ground water near the  lagoons was  found  to
contain heavy  metals  and VOCs.   The  site was included on the NPL in September
1983 and  EPA assumed  lead responsibility.    Notice letters  were  sent  out  to
potentially responsible parties (PRPs) in 1984; however,  because  no financially
viable PRPs were  identified,  EPA initiated a Federal  lead  remedial investigation
(RI) under Superfund  in July  1985.  The ROD was signed June  1, 1987.

Description of Site Work

     The EPA initiated  an RI in 1985  to determine the extent of contamination
in the shallow aquifer and in the soil, and to determine whether contamination
had migrated off site through surface-water runoff.  The RI,  completed in July
1986, determined  that the  soil  was contaminated with lead,  chromium, mercury,
and PCBs;  however, these  contaminants did  not appear to  be migrating from the
site.  Lead, cadmium,  VOCs, and other organic compounds were  also found in the
ground water beneath  the site.  Samples from local  residential wells indicated
that contaminants  had not  migrated  into drinking  water.    However,  a public
health evaluation conducted as part of the RI concluded that contaminated ground
water could potentially  migrate  toward residential wells  and  the sensitive
wetlands.
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Description of Feasibility Study

     The cleanup objectives of the remedial action were to protect human health
and environment from exposure to contaminated soils, prevent  off-site movement
of contaminated ground  water,  and restore contaminated ground water to levels
protective of human health and the environment.  The alternatives were  divided
into four groups:  ground-water  remediation,  soil remediation, no action,  and
no  action with  monitoring  alternatives.   The  following  alternatives  were
considered in the feasibility study  (FS):

          (1)  Ground-water extraction,  air stripping, and disposal
               at privately-owned treatment works;

          (2)  Ground-water slurry wall and cap;

          (3)  Cap or  vegetative or  gravel cover over  the  area  of
               highest  soil contamination;

          (4)  Partial  soil excavation, on-site disposal,  and cap or
               vegetative cover; and

          (5)  Soil excavation and off-site disposal.

     The major applicable  or relevant  and appropriate (ARARs) considered  for
this site were related  to ground water.   Ground water  in  the  uppermost  aquifer
at the site  is comparable to Class I water under the EPA Ground-water Protection
Strategy (GWPS).   The ground water is highly vulnerable to contamination; is  a
source of drinking  water for  nearby residents; and  discharges  into wetlands
inhabited by endangered species,  for example,  the bald eagle, the wood stork,
and the  American alligator.   Resource  Conservation and  Recovery Act (RCRA)
regulations  require  a  level  of cleanup  of contaminated  water  sufficient to
achieve Maximum Contaminant Levels (MCLs).  Other  ARARs identified included  the
Safe  Drinking  Water Act  (SDWA),  Clean  Water  Act  (CWA),  National  Pollutant
Discharge Elimination System (NPDES),  Endangered Species Act (ESA), and National
Ambient Air Quality Standards  (NAAQS) for incineration.

Description of Selected Remedy

     Based on results of the investigations and the comments  received from  the
public, EPA  selected  a remedy that  includes pumping and on-site  treatment of
ground  water and on-site  thermal   treatment  of  contaminated  soil.    This
alternative  meets  CERCLA  preferences  for  treatment  by   permanently   and
significantly reducing  the volume of hazardous substances in  the  ground water
and reducing the  volume of contaminants  in the soil.  The remedy entails  pumping
water  from  the  ground,  applying  treatment technologies appropriate to remove
metals and  VOCs, and  discharging treated water  into  a nearby  stream.    All
contaminated soil will  be  excavated,  and organic contaminants destroyed in an
on-site mobile thermal  destruction unit.   Inorganically contaminated soil will
be  treated  through stabilization and  solidification.   Treated  soil  will be
placed back into the excavated area.
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                        INDEPENDENT NAIL COMPANY SITE
                              FIRST OPERABLE UNIT
                           BEAUFORT, SOUTH CAROLINA

HRS Score: 57.90                                                       NPL Rank: 62

Background

     The Independent  Nail  Company (INC)  site  is  located near Beaufort,  South
Carolina,  40 miles northeast of Savannah,  Georgia.  From 1969 to 1980,  the  Blake
and Johnson Company manufactured screws and fasteners on this 25-acre  site.  As
part of its manufacturing process, the company discharged  approximately 33,000
to 75,000  gallons  per day of plating  wastewater  into an unlined  infiltration
lagoon. The wastewater contained organic cleaning solvents, phosphate,  cyanide,
chromium,  cadmium, lead, mercury, nickel, zinc, copper, and  iron.

     In 1975,  the South Carolina  Department  of Health and Environmental Control
(SCDHEC) discovered that  a break in the  lagoon  allowed wastewater to enter  a
drainage ditch located north of the lagoon.  Further ground-water  investigations
by the State in 1975 and in  1980 indicated that concentrations of  chromium  and
lead in the ground water  exceeded drinking-water standards, and that  cadmium,
nickel, and zinc also were  contaminating  the ground water.  The State took no
action.   In June  1980, INC purchased the  plant  and since  that time has  not
discharged any wastewater  into the  lagoon.   Additional sampling done  in  1985,
however, showed no  metal contaminants at concentrations exceeding  drinking-water
standards.

     EPA added  the INC site to  the  NPL in  September 1984  and assumed lead
responsibility for the  site.  Although EPA  initially determined that  the site
required  no action,  the   SCDHEC  stressed  the seriousness  of  land   disposal
practices at the  site  due to its location  in a major recharge zone.   EPA divided
the site  into  two operable units.   The  first operable unit addressed  soil,
surface-water,  and sediment contamination; the second operable unit  will address
ground-water  contamination.     EPA   completed  the  remedial   investigation/
feasibility study  (RI/FS)  for the  first  operable  unit in July 1987 and signed
the ROD on September 28, 1987.  EPA initiated the  RI/FS  for the second  operable
unit in July 1987.  Both the Blake and Johnson Company  and  INC were identified
as potentially responsible  parties (PRPs).  A notice letter was sent to  the PRPs
but they declined to participate.

Description of Site Work

       The RI,  conducted from September  through  November 1986, determined  the
extent of contamination in  the soil,  surface water, and sediments on  the site
and in the drainage paths  from the lagoon.  The RI  results  indicated that soil
contaminated with cadmium,  chromium, nickel,  and  zinc,  was found primarily in
the lagoon,  in  areas within the  fence,   and  in  two  areas  outside the fence.
Surface-water samples taken  from the ditches showed that only zinc was present
in detectable  quantities.    Samples  taken  from  the  lagoon revealed   elevated
levels  of  nickel  and zinc.   EPA  detected high concentrations  of   cadmium,
chromium,   nickel,  zinc, and cyanide  in  sediment  samples  taken  at  the  same
locations where surface-water samples  were  taken.   An endangerment assessment
indicated that the primary exposure pathway for cadmium, chromium, nickel,  and


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zinc was through  direct contact with surface soils and inhalation of airborne
dust.

Description of Feasibility Study

     The purpose of the FS for the first operable  unit was to identify remedial
actions  to  minimize  soil  and sediment  contamination  and  prevent  further
contamination  of  ground  water.   Nine  potential remedial  alternatives  were
identified:

     (1)  No action;

     (2)  Soil washing  and vegetative cover;

     (3)  Attenuation of  soil contamination  and vegetative cover;

     (4)  Solidification/stabilization  of  soils;

     (5)  Immobilization  of soil by addition of clay  and vegetative
          cover;

     (6)  Immobilization  of soil by addition of lime  and vegetative
          cover;

     (7)  Vegetative cover over lagoon  area;

     (8)  Capping  of lagoon area; and

     (9)  Off-site disposal of  all  contaminated soil.

     Each  alternative  was evaluated  against  the  CERCLA  mandate  of  using
permanent solutions and treatment technologies to the maximum extent practicable
and  the   CERCLA   criteria  of  effectiveness,   implementability,   and  cost-
effectiveness .

     Applicable or relevant and appropriate requirements (ARARs) identified for
the site  were  Occupational Safety  and Health  Act  (OSHA)  regulations,  Safe
Drinking Water  Act (SDWA) Maximum  Contaminant  Levels (MCLs),  Clean Water Act
(CWA),  Endangered  Species Act  (ESA),  Clean Air Act (CAA), and  State Drinking-
Water Standards.

     EPA finalized a Community  Relations Plan in January 1987.   There were no
requests from residents for a public meeting, and  residents  did not comment on
the FS.

Description of Selected Remedy

     The remedy EPA selected consists of treating contaminated soil by means of
stabilization/solidification   (Alternative  4).     Following   treatment,   the
soil/sediment will be placed in the excavated lagoon,  covered with 6 inches of
soil,  and  revegetated.   The results  of the  ground-water investigation in the
second operable unit will determine the necessity  for long-term monitoring.


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     This  alternative uses  permanent treatment to reduce  the mobility  of the
contamination.    It  is  expected  to  be  protective  of human health  and  the
environment and  to  attain ARARs.
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                        PALMETTO WOOD PRESERVING SITE
                            DIXIANA, SOUTH CAROLINA


HRS Score:  38.43                                                     NPL Rank:  420

Background

     The Palmetto Wood Preserving (PWP) site is a decommissioned wood preserving
facility  located in the rural community  of Dixiana, South  Carolina, 6 miles
southwest of Columbia.  Wood treatment operations at the PWP site began in 1963;
processes utilized there include a fluoride-chromate-arsenate-phenol process and
an acid-copper-chromate process.   In  1980,  the  new owners,  Eastern  Forest
Products,  switched to a chromate-copper-arsenate process.

     During late  1981  and  early  1982,  the  South Carolina Department  of Health
and Environmental Control (SCDHEC)  received complaints of green liquids running
off the PWP site  and  puddling on the  adjacent property and roads during heavy
rains.  In response,  SCDHEC inspected  the  PWP site and collected on-site soil
and water samples.  The soil was  found  to be contaminated with  hazardous levels
of chromium and pentachlorophenol  (PCP).

     In April 1983, copper  and chromium were discovered  during the drilling of
a new drinking water  well  200 feet from the site.  As a result, SCDHEC issued
a Consent Order requiring PWP to determine the extent of soil  and ground-water
contamination and to develop a plan for disposing of the contaminated materials.
PWP's subsequent study confirmed  soil and ground-water contamination beneath the
main process area of  the plant site.   Plans for further investigations of the
problem were developed by PWP's contractor but were never  implemented.  At the
end of 1983, SCDHEC turned  over responsibility for future work on PWP to EPA.

     Notice  letters were  sent  to potentially  responsible parties   (PRPs)  in
January 1985.   Two PRPs were found but were  judged not  to  be viable after a
financial assessment.   PWP ceased operations in  1985.   The EPA lead remedial
investigation (RI)  was  initiated in April  1986  and completed  in January 1987;
the feasibility  study  (FS) was  completed in August,  and the ROD  was  signed
September 30, 1987.

Description of Site Work

     The RI conducted by EPA revealed metal contamination in the soil,  including
elevated concentrations of chromium (2,200 ppm) and arsenic (6,200 ppm).  Ground
water below  the   site  also  is highly  contaminated with  copper,  chromium, and
arsenic, at levels  above  standards acceptable for drinking water.  This metal
contamination presents potential cancer risks  through  the following possible
human  exposure  pathways:     inhalation  of  contaminated  dust;   irigestion  of
contaminated soil; and drinking of contaminated ground water.  Upon consultation
with  the  Agency  for  Toxic Substances  and Disease  Registry   (ATSDR), cleanup
criteria for soils were set at 627 ppm for chromium  and  200 ppm for  arsenic.
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Description of Feasibility Study

     The  FS,  completed  by EPA  in  August  1987,  listed the  following cleanup
objectives:   to protect against exposure to  contaminated on-site  soils;  to
prevent  off-site  movement  of  contaminated  ground  water;  and  to  restore
contaminated ground water to protective levels.  Based on  these objectives, the
following alternatives  were  developed and evaluated:

     (1)  Alternatives for Ground-water Remediation:

          •    Slurry wall and  impermeable cap;
          •    Slurry wall with an  encapsulation cell;
          •    Ground-water  extraction, filtration,  ion exchange, and
               off-site  discharge;
          •    Ground-water  extraction,   reduction,  precipitation,
               filtration, and  off-site  discharge;
          •    Ground-water  extraction,   filtration,  ion exchange,
               precipitation, filtration,  and off-site discharge; and
          •    No  action;

     (2)  Alternatives for Soil Remediation:

          •    Surface  capping;
          •    On-site  containment/encapsulation;
          •    Extraction/soil  flushing;
          •    Excavation  and off-site disposal; and
          •    No  action.

     The following applicable or relevant and appropriate requirements (ARARs)
were identified:   Safe  Drinking Water Act (SDWA)   Maximum  Contaminant Levels
(MCLs);  National  Pollutant  Discharge Elimination System  (NPDES)  regulations;
Resource  Conservation  and  Recovery  Act   (RCRA) excavation  and soil  flushing
regulations; Federal and State  ambient air quality standards; and State drinking
water standards.

     At a public meeting to  discuss the  remedial alternatives developed in the
FS,  the public expressed support for treatment of  ground water and flushing of
contaminated soil.

Description of Selected Remedy

     The selected  remedy will consist of  the  following activities:

          •    Extraction  of contaminated ground water,  treatment on
               site to achieve  SDWA MCLs,  filtering,  and discharge off
               site;

          •    Installation  of a municipal water line  or the drilling
               of new wells  for  nearby residents;

          •    Excavation  of contaminated soils;
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          •    On-site flushing of soil with an acidic water solution
               to remove arsenic and chromium;

          •    Removal  of  heavy  metal   ions  in  soil  through ion-
               exchange treatment;

          •    Testing for decontaminant verification;

          •    Pumping  of  flushing  solution  to  an on-site  water
               treatment facility for processing  and recirculation
               through soil;  and

          •    Transport of treated soil back to excavated area, where
               natural aeration will  be supplemented with tilling and
               compaction.

     This remedy is expected  to permanently and significantly  reduce the volume
and/or mobility  of contaminants  in  the  soil and  ground water, and  is cost-
effective in comparison with other alternatives.   The State of South Carolina
concurred with  the selected  remedy,  but pointed out that  its  funds  for  cost
sharing are limited.  Although  the  State presently has funding to cover its  part
of  this  remedial  action,  it  is  concerned  about  funding problems  on future
remedial actions at other NPL sites in the State.
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                              JOHNS-MANVILLE SITE
                              WAUKEGAN, ILLINOIS


HRS Score: 3820                                                      NPL Rank: 428

Background

     The  Johns-Manville disposal  site  is  located near  the City of  Waukegan,
along  Lake  Michigan, in  northeastern Illinois.   There  are approximately  200
homes  within  1  mile  of  the  western  edge  of the  site.    The  site  covers
approximately  120  acres  of land that  is  owned by  the  Manville  Services
Corporation  (previously the Johns-Manville  Sales  Corporation).   The  Manville
Services  Corporation produces  a  wide  range  of  building  materials.    Waste
materials from the Manville plant have  been disposed of in pits on  the site
since  1922; wastes present  include asbestos,  lead, chrome,  thiram,  and xylene.
An  asbestos  disposal  pit,  a sludge  disposal  pit,  and  other  miscellaneous
disposal  pits  still are active.    Materials   from  the Manville  wastewater
treatment system were  also settled out  in  unlined ponds and waterways  at  the
site and periodically transferred  to  the sludge  disposal pit.

     A 1982  study  by  EPA  indicated  that  concentrations  of  asbestos  fibers
ranging in size from 2.5 to 15 micrometers were present at the site and downwind
of the site,  and asbestos  fibers of a  size  less  than  2.5 micrometers  were also
present on site  in elevated  concentrations.  The site was listed on the  NPL in
December 1982.  Enforcement negotiations with the potentially responsible party
(PRP), the Manville  Services Corporation, were  completed in May  1987.  The  ROD
was signed June  30,  1987.

Description of Site Work

     The EPA lead remedial investigation (RI) at the site was completed in July
1985 and  included sampling of air, ground water, soil, and the  waters of Lake
Michigan.   The  RI  indicated that concentrations  of asbestos   fiber  exceeded
applicable health-based water quality criteria at all ground-water and surface-
water  sampling locations.   An air quality survey for lead  and total  suspended
particulates  (TSP) indicated that  air  emissions  from  the site were  a  potential
problem.  In  addition,  elevated levels of metals were found in the  soils.  The
results of the RI indicated the  need to take action  to prevent  the release of
asbestos  and TSPs into  the  air,   and  the  need  to monitor  and,   if  necessary,
remediate contaminants  in the site ground water  and  in Lake Michigan.

Description of Feasibility Study

     EPA completed the  feasibility study (FS) in January 1987.   The objectives
of the remedial  action  were to ensure that:   (1)  releases  of asbestos  to  air
were  eliminated  and that  releases  of  other   contaminants  to the  air  are
mitigated;  (2) direct contact with waste materials and soils was minimized or
eliminated; and  (3)  concentrations of  contaminants in ground water  and surface
water  exceeding  standards for human health and aquatic life were detected  and
effectively remediated.
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      An initial screening process narrowed the alternatives  to the  following:

          (1)  No action;

          (2)  Grading and seeding of the waste materials and soils,
               closure  of  the  asbestos  pit,  and   air  emissions
               contingency plans;

          (3)  Soil covering with vegetation, placement of riprap or
               new soil  on  slopes of the  settling  basins and waste
               disposal area, closure of  asbestos disposal pit, and
               air emissions contingency plans;

          (4)  On-site landfilling, including installation of a multi-
               layer  liner,   multi-layer   cap,  and collection  and
               treatment of leachate and runoff; and

          (5)  Off-site landfilling,  including removal and  disposal
               of soils in a landfill.

All  alternatives included a  ground-water detection  monitoring system  and a
ground-water/surface-water contingency plan.

     Applicable  or relevant and appropriate  requirements  (ARARs)  included  the
Clean Air Act (CAA)  National Emission  Standards  for  Hazardous  Air Pollutant
(NESHAP) requirements and National Ambient Air Quality Standards (NAAQs),  the
Clean Water  Act (CWA), Illinois Water Quality Standards, the Safe Drinking Water
Act  (SDWA),  the Great Lakes  Water  Quality  Agreement  of 1978, the  U.S.  EPA
Ground-water  Protection  Strategy,  the Resource Conservation and  Recovery  Act
(RCRA),   the  Occupational Safety  and Health  Act  (OSHA),  and other  State of
Illinois requirements.

     Approximately 20  people attended  a  public  meeting  in  February  1987 to
discuss  the  RI/FS.  Ten individuals and  organizations submitted comments during
the public comment period on the FS.   The Manville  Sales Corporation submitted
comments disagreeing  with the proposed thickness of the cover.  Other commenters
expressed concern about  funding for  a cleanup, the use of the property after
cleanup, the degree of endangerment,  and the public  health effects presented by
the site.

Description of Selected Remedy

     The  recommended  alternative contained   multiple approaches,  including
grading  and  covering  of  the waste materials  and  soils  at  the  site,   and
installing a  cover of  vegetation.   The active  disposal pits will continue to
operate  but the  asbestos pit will be closed  in June 1989  and covered.  Riprap
will be placed on the  slopes  of the  settling  basins to prevent erosion, and a
ground-water and surface-water detection monitoring system will be established
on site  to detect any leaching of  contaminants.  In  addition,  an air monitoring
system will  be used to determine whether the remedy reduces airborne contaminant
levels.   Miscellaneous remedies, such as the cleanup of debris, fencing,  and the
posting of signs, also will be instituted.


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     The State of Illinois concurred with  the  selected remedy.   In response to
public comments, an air monitoring program, an associated contingency plan, and
a  sampling plan for  active waste  disposal areas  on site were  added  to the
recommended alternative.

     The alternative is expected to meet the ARARs for  the site.  Presently, the
site achieves the NAAQs for lead.  However, initial grading and construction at
the  site  may temporarily  generate  levels  of contaminants  above  the  NAAQ
standards.  Soil covering should reduce the contaminant levels in Lake Michigan
below EPA Ambient Water Quality  Criteria and Illinois  Water Quality Standards.
Additionally, the  alternative fulfills  the CERCLA preference for  a  permanent
remedy.
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                           ENVIRO-CHEM CORPORATION/
                         NORTHSIDE SANITARY LANDFILL
                              ZIONSVILLE, INDIANA


ECC HRS Score: 46.44                                              ECC NPL Rank: 240
NSL HRS Score: 46.04                                              NSL NPL Rank: 249

Background

     The Enviro-Chem Corporation (ECC)  and the Northside  Sanitary Landfill (NSL)
sites  are  located  in  a   rural  area of   Indiana,  10  miles  northwest  of
Indianapolis.    ECC,  a  former  solvent  processing  and  reclaiming  facility,
occupies about 7 acres immediately west of  NSL,  a 70-acre landfill containing
both hazardous and non-hazardous wastes.  Farmland borders the sites and about
50 residences are located within a mile of the sites.   Finley  Creek, which flows
along the eastern  and  southern edge of the  NSL  site, eventually  feeds into a
reservoir supplying approximately 6 percent  of the drinking water for the City
of Indianapolis.

     ECC began operations  in  1977  involving the recovering,  reclaiming,  and
selling of  primary  solvents,  oils,  and  other  industrial  wastes.    ECC  was
permitted to dispose of still bottoms and oily wastes at NSL.  Accumulation of
contaminated storm water, poor management  of drum inventory,  and several spills
prompted EPA and  State  investigations of the ECC  site.   In 1981, after a number
of  violations,   the Boone  County  Circuit  Court   issued  a  Consent  Decree
prohibiting  ECC  from using  the NSL  for  disposal of wastes.   ECC  failed to
satisfy the Consent Decree  and was  ordered to stop operations.  In August 1982,
ECC was found to be insolvent.  From  1983  to 1984,  surface  contaminants were
removed from the site and treated.   The ECC site was listed on the  NPL in
September 1983.

     The NSL site began  operations sometime before  1960 and was first ordered
to cease  operations in  1974 due  to  reported operational deficiencies.   Use
resumed and reports of  disposal of unapproved waste at NSL continued through the
late 1970s.  In  1980, the  owner  filed  a Resource  Conservation and Recovery Act
(RCRA) Part A application  and  operated as an existing hazardous waste disposal
facility until November 1985 when EPA denied a RCRA Part  B application.  The NSL
site was placed on  the  NPL  in September 1984.  In February 1987, after a series
of investigations,  the  Indiana Solid Waste Management Board  ordered  NSL to
accept no additional solid waste except that needed to  contour the site.  NSL
has appealed and the results of  the hearing  are not known at this time.

     Because similar remedial  actions  are required  at both sites,  a joint ROD
was signed on September 25, 1987.  One thousand potentially responsible parties
have been identified and  three steering committees exist  to organize the effort:
(1)  ECC  settlors  (1983  Decree),  (2)  ECC non-settlors, and  (3)  NSL Steering
Committee.   The  landfill owner represents himself as a separate  entity.  EPA
will be seeking  cleanup funds  and  reimbursement  for previously incurred costs.
The  ECC  settlors have been released from  responsibility  for most previously
incurred costs and half of  the remedial investigation/feasibility study (RI/FS)
costs.
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Description of Site Work

     Emergency actions at the ECC site have eliminated major surface sources of
contamination.   The  contamination  remaining in  the  soil  includes  volatile
organic  chemicals  (VOCs),  polynuclear   aromatic  hydrocarbons   (PAHs),   and
polychlorinated  biphenyls  (PCBs).    The  EPA lead RI,  completed in  1986,  also
indicated organic  contamination in  the  ground water  off site.   Ground-water
contamination appears  in  a  glacial till water-bearing unit below  the  site due
to leaching.

     As of April 1987, NSL was continuing to operate as a solid waste landfill.
The RI  for  that site  revealed contamination  in  the  subsurface soil,  surface
water and sediments,  leachate, and ground water.   Contaminants  include volatile
organics, oil and grease, inorganics, and  pesticides.

Description of Feasibility Study

     Although  a separate  FS  was  conducted  for  each  site,   a third  report,
entitled  "Combined Alternatives Analysis (CAA)   Report,  NSL and  ECC,"  was
prepared to discuss a combined remedy.  Remedial goals were identified for each
medium:  soil and landfill  contents, landfill leachate,  ground water,  surface
water,  and sediment.   The goals were to  minimize direct  contaminant  contact,
control  migration  to  ground and   surface  water,  and  minimize   contaminant
consumption.   Nine alternatives  were evaluated:

          (1)  No action;

          (2)  Soil cover and  leachate collection and treatment with
               access restrictions;

          (3)  RCRA cap  and leachate collection and  treatment, with
               access restrictions;

          (4)  Soil   cover,   leachate    collection,    ground-water
               interception and  treatment, with access  restrictions;

          (5)  RCRA    cap,     leachate    collection,     ground-water
               interception and  treatment, with access  restrictions;

          (6)  RCRA cap, leachate collection,  ground-water isolation
               and treatment, with access  restrictions;

          (7)  RCRA cap, leachate collection,  ground-water isolation
               and treatment,  ECC soil vapor  extraction,  with  access
               restrictions;

          (8)  RCRA cap, leachate collection,  ground-water isolation
               and  treatment, ECC   soil   incineration,  with  access
               restrictions; and

          (9)  On-site RCRA landfill  with  access restrictions.
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     The alternatives were evaluated for compliance with  CERCLA  cleanup  goals,
including preference  for  treatment that permanently and  significantly reduces
the volume,  toxicity,  or mobility of  hazardous  substances.   The  evaluation
considered the  following applicable or  relevant  and appropriate  requirements
(ARARS):  RCRA closure and post-closure requirements;  Indiana closure and post-
closure requirements; State of Indiana Water Quality Criteria;  RCRA and Indiana
Environmental Management Act measures to prevent releases  of contaminants;  RCRA
requirements for corrective action; RCRA ground-water protection standards and
concentration limits;  the Clean Water Act  (CWA)  National Pollutant  Discharge
Elimination  System (NPDES);  Executive  Orders 11988 and  11990 for  Floodplain
Management and  Protection of Wetlands;  and  the  Indiana Department of Natural
Resources Flood Control Act.

Description of Selected Remedy

     EPA's recommended alternative (Alternative 5) includes a RCRA-compliant cap
and surface controls,  monitoring, leachate collection,  ground-water interception
and treatment, and access restrictions.  The selected remedy is consistent with
the CERCLA goal  of mitigating and minimizing threats  to  human health and the
environment.   The selected remedy is expected  to attain ARARs identified for the
two sites.   Public comments received  on the  FS  and  the  CAA  Report  indicated
residents were  concerned  that a  permanent   remedy be  introduced  as soon  as
possible at the sites.  The State of Indiana concurred with the selected remedy.
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                          MARION/BRAGG LANDFILL SITE
                        SOURCE CONTROL OPERABLE UNIT
                                MARION, INDIANA


HRS Score:  3525                                                    NPL Rank: 530

Background

     The Marion/Bragg Landfill, located just outside the city limits  of Marion,
Indiana, 65 miles northeast of Indianapolis, was used as a sand and gravel  quarry
from 1935 until  approximately 1961.  From  1949  through 1970,  Radio Corporation
of America  (RCA) leased and used portions of  the  site for  industrial  refuse
disposal.   Concurrently, from 1957 to 1975, Bragg Construction  leased and  used
the  site  as  a  municipal  landfill.    Indiana  State  Board  of  Health   (ISBH)
inspections indicated that the landfill was operated in an  unacceptable manner,
although ISBH never formally  closed the  site.  Flammable drummed waste often was
emptied and mixed with the landfill wastes, causing fires.  Drums allegedly  were
rinsed and  resold.   Other violations included lack of  daily  cover, burning of
waste, and pond  encroachment.

     Notice  letters were  issued to  potentially responsible parties (PRPs),
including Mr.  Delmar  Bragg,  General Plastics  Corporation,  RCA,  the  City of
Marion, and the Marion Utility Services Board,  and a meeting was held in November
1985 to provide  the PRPs an opportunity to work  cohesively and to respond to
EPA's work plan.   In December 1985,  Enforcement and  Regional Counsel  determined
that EPA should  initiate the remedial investigation/feasibility  study (RI/FS).
Little or no interaction has  occurred with the PRPs  since that time.  The RI/FS
was  completed in July  1987,  and the ROD  was signed  September  30,  1987.   An
interim remedy for  source  control was  selected for this site pending further
ground-water  studies.

Description of Site Work

     EPA initiated the RI in March 1985 and completed it in June  1987.  Results
indicated  that  surficial soils at  the site were  contaminated with  Bis  (2-
ethylhexyl) phthalate,  cadmium, lead, mercury,  and  several  polycyclic aromatic
hydrocarbons  (PAHs).   Two leachate  seeps  at the site were  contaminated  with
arsenic and other  inorganic  metals.   PAH and arsenic contamination  in  the
leachate seep exceeded  levels acceptable for  direct  contact  (1 x 1(T6) .

     Ground   water   beneath   the   site  was   contaminated   with  benzene,
trichloroethylene,   and arsenic at  levels above  Clean Water Act  (CUA)  Water
Quality Criteria (WQC)  for  human  health.   Other  ground-water contaminants
included phthalate,  ammonia, barium,  and some heavy metals.  The Mississinewa
River,  the  major receptor  of  ground  water  from the  site,  was found  to be
contaminated  with ammonia  at levels above Indiana  WQC.  In  addition, on-site
ground water contained ammonia at  levels that have the potential to harm aquatic
life in the river.
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Description of Feasibility Study

     The FS,  completed by  EPA in July 1987, identified the  following  remedial
action goals for the site:   (1)  minimize risk from  direct contact with  PAH-
contaminated surface soils and  the on-site  pond;  (2) minimize migration  of
arsenic and other contaminants in leachate seeps  and surface soils to  ground
water and off-site surface water; (3) minimize risk from  direct  consumption of
contaminated ground  water;  and (4)  minimize  migration of contaminated  ground
water  to  surface  water.     Based  on  these  goals,   the  following  remedial
alternatives were developed and analyzed:

          (1)   Installation of an Indiana Sanitary Landfill Cap (a 2-
               foot  clay-type   cap   and   6  inches  of   top-soil),
               construction of a flood protection  levee  around  the
               100-year floodplain,  monitoring of ground  and surface
               waters,  and  deed restrictions  on use   of  shallow
               drinking water wells;

          (2)   Installation of a  Resource Conservation and  Recovery
               Act (RCRA)-compliant  cap  (and  all  the components  of
               Alternative 1);

          (3a)  Installation of a  slurry wall, ground-water  pumping,
               and  on-site  treatment  (and all  the   components  of
               Alternative 1);

          (3b)  Installation of a  slurry wall, ground-water  pumping,
               and off-site discharge  to  local treatment plant  (arid
               all the components of Alternative 1);

          (4a)  Similar  to  Alternative 3a,  except  construction of  a
               RCRA-compliant  cap rather  than  a sanitary  cap;

          (4b)  Similar  to  Alternative 3b,  except  construction of  a
               RCRA-compliant  cap rather  than  a sanitary  cap;  and

          (5)   No action.

     The following applicable  or relevant and  appropriate requirements (ARARs)
were  identified  for the  site:   Indiana  Sanitary  Landfill requirements,  the
Indiana Floodplains Control Act,  Indiana WQC,  and RCRA surface-water monitoring
requirements.

Description of Selected Remedy

     In the remedy selection  process, EPA decided that additional ground-water
studies were  needed  in order to  select a ground-water  remedy that  assures
protection of human health.  Therefore,  the  ground-water treatment alternatives
(3a,  3b,  4a,  and 4b) were deferred,  and   Alternative  1  was selected as  an
interim remedy.  In  concurrence  with  the execution of the  interim remedy,  EPA
will  conduct   fish-sampling,   ground-water  release studies,  and ground-  and
surface-water monitoring.


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     The  selected  remedy  is   implementable   and  cost-effective.    Long-term
effectiveness  and permanence  will  be evaluated  best  when  the  ground-water
remediation  is  completed.   Permanent treatment-based  solutions,  particularly
incineration alternatives, were considered but screened out due to technical and
cost considerations.  Such alternatives would  take 25 to 100 years to complete,
at a cost of $404 million to $3.4 billion.
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                     SEYMOUR RECYCLING CORPORATION SITE
                               SEYMOUR, INDIANA

MRS Score: 58.15                                                       NPL Rank: 57

Background

     The Seymour Recycling Corporation  (SRC)  site  is  located  2 miles  southwest
of  Seymour,  Indiana,   in an area  used  primarily  for  agriculture.     From
approximately 1970  to  early 1980, SRC  and its corporate predecessor, Seymour
Manufacturing Company,  processed,  stored, and  incinerated chemical wastes  at the
site.

     In March 1980,  100 homes were evacuated after a chemical  reaction released
toxic fumes from the facility.   The facility  was  subsequently  closed due  to
failure to  comply with  the terms  of  a 1978 agreement  with  the State of Indiana
to improve  waste  management  practices and to cease receiving wastes.  In May
1980,  the United States filed suit against  the owners and operators of  the  site.
Two potentially responsible  parties  (PRPs) removed  several  thousand drums from
the site, and EPA took  action to  restrict  access  and  control  runoff.  In  1981,
EPA removed chemicals  from tanks at the site and disposed of those wastes  at
authorized  disposal sites.   In the Fall  of 1982,  the  United States and certain
companies that allegedly sent waste to the  site reached a settlement agreement.
Under  the  terms of   the  consent   decree,   the  settling   defendants removed
accumulated wastes and  contaminated  soil from the  site.

     From 1982 to 1984, EPA and the State conducted a surface  cleanup, removing
drums, tanks,  and soil  for  off-site disposal.   Preliminary  sampling efforts
indicated that over 70  potential carcinogens, teratogens,  mutagens,  and  acute
and chronic toxicants were present in the soil,  surface water, and ground  water
at the SRC  site.

     A case management  order was  issued in  1984  for negotiations between the
defendants and the EPA.  There are approximately 60 defendants, currently  named
by the United States  in the ongoing suit,  who have,  in  turn,  introduced  60
additional third-party defendants.  EPA initiated  a Remedial Investigation (RI)
that was  completed in May 1986.  A Phased Feasibility Study  (PFS)  that,  evaluated
the stabilization of  the ground-water  contamination plume emanating from the
site was  completed in  August 1986.   The  ROD  was signed  September  4,   1987.
Negotiations with PRPs  are ongoing.

Description of Site Work

     In  1983,  EPA  initiated  an RI  to determine  the nature  and  extent  of
potential hazards remaining at the site.  The  endangerment  assessment  estimated
potential impacts on human health and the  environment.  The RI identified the
following as major  risks associated with  the site:   1) off-site migration  of
volatile  organic compounds   (VOCs);  2) potable   use  by  humans  of  shallow,
contaminated ground water on site; 3) exposure of  humans to contaminants  in on-
site soils through site use;  and 4) on-site and off-site exposure  of terrestrial
and aquatic organisms to contaminants from the  site.
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     EPA collected soil samples during 1984 and 1985 to determine the extent of
the contamination of  the  soil.   Additional sampling was conducted by the  U.S.
Fish  and Wildlife  Service between  1983   and  1985.   Ground-water  monitoring
conducted at the SRC  site by EPA and various contractors detected the presence
of a  ground-water  contaminant plume containing a high concentration  of VOCs.
In addition, analyses of tissues from animals  captured in  the  area surrounding
the  SRC site  indicated  that  some  contamination  from  the site  migrated  to
surrounding land areas and surface waters.

Description of Feasibility Study

     The PFS was completed in 1986 to evaluate  the stabilization of the ground-
water plume.  Remedial alternatives under  consideration in the PFS were:

          (1)  No action;

          (2)  Off-site soil disposal and ground-water extraction
               and treatment;

          (3)  On-site soil disposal and ground-water extraction
               and treatment;

          (4)  On-site   soil   incineration   and   ground-water
               extraction and treatment;

          (5)  Multi-media soil cap and ground-water extraction
               and treatment;

          (6)  In-situ soil washing, multi-media cap, and ground-
               water  extraction and treatment; and

          (7)  Vapor  extraction,  multi-media  cap,  and  ground-
               water  extraction and treatment.

     Federal  applicable  or  relevant  and  appropriate requirements  (ARARs)
considered included Maximum Contaminant Levels (MCLs), MCL goals  (MCLGs),  and
health  advisories  under the Safe  Drinking Water Act  (SDWA);  MCLs,   Alternate
Concentration  Limits   (ACLs),   and  background  levels  under   the   Resource
Conservation  and Recovery  Act  (RCRA);  verified  reference doses  (RFDs)   for
noncarcinogens developed by an  intra-agency EPA workgroup; carcinogen potency
factors (PFs) developed by EPA; and Water Quality Criteria (WQC) under the Clean
Water Act  (CWA).  Indiana  State  ARARs  considered included narrative  and  non-
degradation water quality standards, and numerical drinking water standards for
public water supplies.  Other  State standards considered were closure and post-
closure requirements and land disposal restrictions  under  RCRA.

     The community of Seymour,  Indiana, has  been  concerned about the  SRC  site
since 1976.   The  city  used a court-held trust fund established as part of a  1983
settlement between EPA  and several PRPs to  extend  the city's municipal water
system  to the  subdivision on  which the site is located.   At a public meeting
held by EPA  on  the October 9, 1986,  Seymour community participants expressed the
desire that remedial action be implemented as  soon  as  possible.


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Description of Selected Remedy

     The  remedy selected for  the  SRC site was a  modification of  the  seventh
alternative  listed  above:  soil vapor extraction,  multi-media cap,  and  ground-
water extraction and treatment.  The soil vapor extraction system selected will
remove a  substantial  amount of the VOCs present in the soil.   The  application
of soil nutrients will stimulate biodegradation of the remaining non-volatile
organic compounds  remaining in  the  soil.   Construction  and maintenance  of  a
multi-media  cap will provide protection  from  direct contact with the remaining
contaminants, reducing the cancer health risk  to humans from direct contact with
soil on site and reducing soil exposure  risk  for terrestrial animals.   Capping
will also prevent the small concentrations of slow-moving VOCs remaining in the
soil from further contaminating the ground water.   The ground-water  pumping and
treatment system will remove nearly all of the VOCs in the ground water,  reduce
the cancer risk to humans, and also prevent further contamination of the ground
water.  As described above,  the selected remedy employs permanent solutions and
treatment technologies and  is  expected  to  satisfy  ARARs.
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                            LIQUID DISPOSAL INC., SITE
                                UTICA, MICHIGAN


HRS Score: 6328                                                      NPL Rank: 24

Background

     Liquid Disposal Inc., (LDI) is  a 6.5-acre  site located about 20 miles north
of Detroit in a residential and light industrial area.  The site is bordered by
the Clinton River and its floodplain and by  a  nature  study area.   LDI  operated
from 1968 to  1982 as a commercial incinerator  of  liquid waste.   Major  features
of the  site  include a high-temperature  incinerator,  a waste liquid lagoon,  a
scrubber water lagoon, and numerous  above- and below-ground storage tanks.

     LDI was  closed  in  1982 when  two  workers  were  killed  in an  industrial
accident.  Since that time,  EPA has  completed four immediate removal actions to
respond  to  hazardous substances  and  waste  stored in  the  waste  oil lagoon,
storage tanks and drums, scrubber lagoon, and ash sludge piles.   As a result of
these actions, there no longer are surface waste sources at the  site.   However,
waste sample jars and old equipment  and  containers do remain at the site.   The
on- and off-site soil and  ground water  in the upper aquifer is contaminated both
by organic  and inorganic chemicals,  including PCBs,  lead,  trichloroethylene,
benzene, toluene, and phenol.

     In  September  1983,  the Michigan  Department  of Natural  Resources (MDNR),
through   a   cooperative    agreement  with    EPA,   initiated   the   remedial
investigation/feasibility study  (RI/FS).  The final  RI  was completed in  May
1987,  the  FS  report was completed in  August 1987,   and the  ROD was  signed
September  30,  1987.     EPA  has  identified  approximately  850   potentially
responsible parties  (PRPs) for the LDI site.   Notice letters pursuant to  CERCLA
have been  sent to  all  known PRPs.   EPA's National  Enforcement Investigation
Center has compiled information received from PRPs into  a  draft transactional
data base.  A PRP  Steering  Committee has been organized, and EPA  is currently
negotiating with PRPs to have them conduct the remedial action.

Description of Site Work

     The State lead RI investigated contamination of the soil and ground water.
Results indicated that on-site concentrations of the contaminants generally  are
higher than off-site concentrations.

     Although there are no current users of  ground water downgradient  from  the
site,  the  effects  of  LDI   on  the  bedrock  aquifer  also  were investigated.
Potential sources  of aquifer contamination  included  leaks from the injection
well, migration of  contaminants from the surface reaching the  aquifer through
a poorly sealed well,  and  natural  causes.  There is strong evidence  that surface
contaminants have only a slight chance of migrating through  an  underlying clay
layer.    The  high  levels  of downgradient  contaminants  are not  believed to
originate  from  the  site;   thus,   the  ROD  only   addresses  upper  aquifer
contamination.
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     The RI also  included  an  endangerment assessment and exposure assessment.
Possible routes of exposure that pose health risks include direct contact with
soils and leachate, and ingestion  of the  ground water.  In addition,  there  is
potential risk to the  Clinton River due to acute or chronic  contamination of the
organisms in the wetlands.

Description of Feasibility Study

     The FS,  completed by the State in August 1987, evaluated remedial treatment
and containment  technologies.   Remedial  alternatives  were developed  from the
technologies that met  the criteria of achieving response objectives, controlling
or treating  the  chemicals  present at  the site, being  applicable  to  the site
conditions,  and   meeting   performance,   reliability,   and  implementability
standards.  Seven alternatives were evaluated in  detail:

          (1)  No action;

          (2)  On-site  land  disposal of  equipment and debris,
               construction of a slurry wall and impermeable cap
               containment  system,  and  an air-stripping ion
               exchange  ground-water extraction  and  treatment
               system;

          (3)  Off-site  disposal  of  equipment  and debris  at a
               sanitary landfill, off-site land disposal of soil
               at a Resource Conservation and Recovery Act (RCRA)
               landfill, and installation of an activated carbon
               ground-water extraction and  treatment system;

          (4)  Off-site  disposal  of  debris  and equipment  at a
               sanitary  landfill,  on-site incineration of soil
               and waste,  and  installation of  an ultraviolet
               ozonation, flocculation, and precipitation ground-
               water extraction and treatment system;

          (5)  Off-site  disposal  of  debris  and equipment  at a
               sanitary landfill, vacuum extraction combined with
               solidification and fixation of the soil and waste,
               and air  stripping  and ion exchange ground-water
               extraction and treatment;

          (6)  Off-site disposal of debris and equipment, on-site
               biodegradation and solidification and fixation  of
               soil  and  waste,  and  biological  ground-water
               treatment with flocculation and precipitation; and

          (7)  On-site land disposal  of the debris and equipment,
               on-site  solidification  and fixation of  the soil
               and waste,  on-site ground-water extraction and
               treatment using  air stripping  and ion  exchange
               technology,  and construction of a slurry wall and
               impermeable cap system.


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     Major State and Federal applicable or relevant and appropriate requirements
(ARARs) included RCRA, the Occupational Safety and Health Act (OSHA),  the Clean
Water Act  (CWA) ,  and  the Toxic  Substances  Control Act  (TSCA) .    State  ARARs
included the Michigan Hazardous Waste Management  Act,  the  Michigan Solid Waste
Act, the Michigan Air Pollution Act, and the Michigan Water Resources Commission
Act.

     Community involvement at the site included public meetings held at regular
intervals throughout the RI/FS process.   At  the  request of several  PRPs,  the
public comment period on the FS was extended.   Community  concerns at  an August
1987 public meeting addressed  the solidification and  fixation process because
the short-term impacts from  them  may include  toxic  air emissions.

Description of Selected Remedy

     The  recommended  remedy  is  Alternative  7.    Other  alternatives  were
eliminated for not meeting the  CERCLA preferences  for treatment and the required
compliance with ARARs.   The alternative  chosen is  the most  cost-effective and
is  designed  to meet all  ARARs.   Hazardous  substances  in the  soil will  be
solidified to  reduce their  mobility  and toxicity; however,  they will not  be
destroyed permanently.   Accordingly,  the  site will  be  reviewed under  CERCLA
section  121(c) every 5  years  to ensure  that  the  remedy continues  to  be
protective.   The alternative chosen has been  endorsed by  the State.
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                           ROSE TOWNSHIP DUMP SITE
                          OAKLAND COUNTY, MICHIGAN


HRS Score: 50.92                                                      NPL Rank: 166

Background

     The Rose Township Dump  site  covers 110 acres in  a wetland area in  rural
Rose Township, Oakland County, Michigan.  After being  farmed  in the  1950s, the
site was used illegally as a  dump.   Operators  placed an estimated 5,000  drums
on one portion of the site, contaminated other  areas with lead battery sludges,
and discharged bulk waste onto the soil surface and into shallow pits.

     In 1968, the Oakland County  Health Department (OCHD)  was notified of the
illegal dumping.  Over the next several years,  a  number of legal actions were
unsuccessfully brought against the waste  hauler and  property owner.   In  1979,
the Michigan Department of Natural Resources (MDNR) sampled drums and domestic
wells at  the site.    The  results prompted  the State  Toxic  Substance Control
Commission  to  declare an  emergency  and  to  remove more than  5,000 drums of
contaminants from the site.   In  1980  and 1982,  MDNR  conducted hydrogeologic
studies of  the  site by installing monitoring  wells and taking soil samples.'
These  initial  investigations  indicated  that  organic  chemical contamination
extended  below  the  shallowest  aquifer and that additional  information was
necessary to define the extent of the contamination.

     The site was placed  on the  NPL in 1982.   In October 1982,  EPA notified
seven potentially responsible parties  (PRPs) of their potential liability and
of EPA's intent  to  conduct a  remedial  investigation/feasibility study (RI/FS)
at the site.  Upon  completion of  the RI/FS  in  1986,  EPA issued special notice
letters to 29 PRPs and held an informational meeting with 11 PRP representatives
on July 17,  1987.   The ROD was signed  September  30,  1987.  Negotiations have
been held and a good faith offer  from the PRPs was due  in  late 1987.

Description of Site Work

     The purpose of the RI was to assess site conditions,  chemical contaminant
distribution, and environmental and health risks  at  the site.  Results of the
RI  indicated that  ground  water,  surface soils,   and   adjacent  wetlands  were
contaminated.  Contaminants of concern  found  on the site were  lead, zinc,'  PCBs,
and volatile and semi-volatile organic compounds  (VOCs).   Ground  water was
contaminated with several metals,  including lead,  iron,  and zinc, and sampling
results  identified   two  ground-water  contamination  plumes   containing   vinyl
chloride,  xylene, toluene, and  benzene.  The  principal threat to surrounding
communities  is  from potential contamination of nearby  wells,  the  nearest of
which is 1,600 feet from the site.  Although access to  the site is restricted,
hunters, snow mobile riders,  and the  abundant wildlife  on site are at risk from
potential exposure to high surface soil contamination.   There is also a threat
to surrounding wetlands via drainage pathways.
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Description of Feasibility Study

     The FS  identified  three  specific areas of concern:  ground-water  plumes;
soil contamination; and drainage pathways to the wetlands.  Following an  initial
screening, five remedial alternatives were  compiled:

           (1)  No  action, except for monitoring;

           (2)  Excavation of  contaminated soils,  with  off-site
               land disposal;

           (3)  Excavation, with on-site thermal destruction  of
               organics and on-site disposal of ash;

           (4)  Excavation, with soil aeration to remove VOCs and
               off-site land disposal of metals and  PCBs; and

           (5)  Impermeable capping  of site with in-situ vacuum
               extraction of VOCs.

Each remedial alternative included extraction  and treatment of ground water by
air stripping and  carbon absorption.

     Major Federal and State applicable  or relevant and appropriate requirements
(ARARs) identified for the site  included:  Maximum Contaminant Levels (MCLs)  and
the proposed Maximum Contaminant Level Goals (MCLGs) for chlorobenzene under  the
Safe  Drinking Water  Act  (SDWA);   substantive requirements  of  the Resource
Conservation and Recovery Act  (RCRA)  and Michigan Act  64 concerning  treatment
and  storage  of  contaminants  on  site;  RCRA  regulations  concerning  design,
construction, operation, and  maintenance of incinerators;  and Toxic  Substance
Control Act  (TSCA) requirements  for disposal of PCB-contaminated  soil.

     A  public  comment period for  the  RI/FS began  on  June 29,  1987,  and  was
extended beyond  its  30-day deadline  to  August 27,  1987, in response  to public
request.   A  public meeting was held on July  1,  1987,  to discuss  the proposed
remedial plan.  The public supported the remedy selected (discussed below).

Description of Selected Remedy

     The preferred remedial action alternative  consisted of soil excavation,  on-
site thermal destruction of contaminants, ground-water extraction and treatment,
and  site  fencing  and  monitoring  (Alternative   3).   Of   the   alternatives
considered,  only  the  selected  remedy  is expected  to satisfy all ARARs  and
provide for permanent destruction of contaminants.   Contaminated  soils  will be
excavated  and  incinerated to  remove  the  risk of direct  contact and  further
ground-water contamination.  Existing contaminants will be removed from ground
water so that the aquifer will be of potential use  for potable water in  6 to 10
years.

     An  infrared  incinerator  will  be  used  in  a  pilot   test  to  destroy
contaminants on site.  This  technology was chosen because it is demonstrated to
have  destruction  and  removal  efficiencies  of 99.9999+  0/0  for wastes with


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elevated PCB  concentration and  to  "fix"  heavy metals  into the resulting ash.
Also, it is estimated that the  infrared  unit will have lower associated costs
than a rotary kiln  incinerator.   If the resultant ash  passes EP toxicity test,
it will be backfilled on site.  If not,  it will undergo  further treatment before
burial.
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                               FMC CORPORATION
                         GROUND-WATER OPERABLE UNIT
                              FRIDLEY, MINNESOTA


HRS Score:  65.50                                                     NPL Rank:  17

Background

     The FMC site is located in Fridley, Minnesota, just north of Minneapolis.
The site lies approximately 1,000 feet east of  the Mississippi River, one-half
mile  upstream from  Minneapolis'  drinking  water  intake,  which  serves about
500,000 people.  The site  is  divided into several sections, including the 13-
acre FMC lands and the  5-acre  Burlington Northern Railroad (BNR) lands.  Both
are located immediately  south  of  the FMC Ordnance manufacturing complex.  The
Naval Industrial Reserve Ordnance  Plant  (NIROP)  is located directly north of the
FMC and BNR lands.

     From  1941  to  1964,  Northern Ordnance,  Inc.,  operated a  naval ordnance
manufacturing complex,  later purchased by FMC.  From approximately 1945 to 1969,
the FMC and BNR  lands  south of the  complex were used for the incineration and
disposal of paint,  oils,  solvents, and other substances.  In 1980,  the  Minnesota
Pollution Control Agency (MPCA) received a complaint  regarding past disposal  at
the BNR lands.   MPCA required FMC to investigate  both the FMC  and BNR  lands.
The FMC investigation revealed that  past disposal  had resulted in contamination
of ground water and of the Mississippi River.

     The FMC site was proposed for inclusion on the NPL in 1982.  Under  a 1983
Consent Order with  EPA,  FMC  excavated and  contained contaminated  soil and
initiated  a  remedial   investigation/feasibility   study  (RI/FS)   to  evaluate
alternatives  for a ground-water  remedy.   The  final FS  for  the ground-water
operable unit was completed in 1985,  and the  ROD was  signed September  30, 1987.
The U.S. Department of  the  Navy  is  conducting a separate RI/FS to address the
NIROP manufacturing facility and surrounding area.

Description of Site Work

     The  RI  indicated  that ground  water beneath  the FMC  and BNR  lands   is
contaminated with trichloroethylene  (TCE),  benzene,  toluene, and other volatile
organic compounds (VOCs) .  Because ground water at the  site  discharges into the
Mississippi  River,  consumers  of  drinking  water  that  flows  through  the
Minneapolis intake  could be  exposed to an  increased health risk.   Although
ground water  in  the  contaminated areas currently is not  used  as  a source for
drinking water,  the  long-term risk  of  exposure through  the potential  use  of
private wells is a matter of concern.

     Data  derived  from samples taken at  the Minneapolis water  intake  on the
river indicated that TCE contamination, some of which can be traced to the FMC
and BNR lands, threatens to exceed the Maximum Contaminant Level (MCL) for TCE,
as established by the Safe Drinking Water Act  (SDWA).
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Description of Feasibility Study

     The purpose  of  the FS was to  identify a remedial alternative  that  would
minimize potential ingestion of contaminants directly from ground water or from
the Mississippi River.   The objective  of  the proposed response action was  to
keep the health risk at any  existing receptor under  10~6 additional  lifetime
cancer deaths.  The following remedial  alternatives were  formulated:

           (1)  No action;

           (2)  Long-term monitoring;

           (3)  Excavation  and  off-site   disposal  or  on-site
               containment;

           (4)  Capping;

           (5)  Physical containment via  barrier wall and pumping;

           (6)  Hydraulic containment  of ground water;

           (7)  Ground-water treatment and/or  disposal;

           (8)  Alternative water supply; and

           (9)  In-situ biological treatment.

     Applicable or relevant and appropriate requirements (ARARs)  identified for
this  operable  unit   included  Federal  and State  drinking  water  standards,
particularly Federal MCLs and levels  set forth by the  State  of Minnesota.   The
discharge  of treated  water  may be  subject  to  requirements of  the  National
Pollutant Discharge and Elimination System (NPDES) program and the Clean  Water
Act (CWA).   Treatment involving  air  emissions  may be subject to standards of the
Clean Air Act (CAA) and relevant State  requirements.

     Since 1983,  State  officials have kept local public  officials  informed  of
events at  and proposals for  the FMC  site.   State officials  discussed  findings
of the RI/FS in meetings held in December 1985 and October 1986.  Additionally,
in October 1986,  the  proposed Consent Order and plan for remedial action were
presented to the public for comment.  The proposed remedy  (discussed below) has
the broad support of the public and local  government officials.

Description of Selected Remedy

     EPA's recommended solution is a hybrid  approach  that  combines hydraulic
containment  through  extraction  wells (Alternative  6),  discharge  of untreated
ground water to a publicly-owned treatment works  facility (Alternative 7), and
long-term monitoring (Alternative 2) .  The enforcement of existing institutional
controls will ensure that ground water is not  used in areas between the  site and
the Mississippi River while the extraction system is operating.
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     Five wells  will be  used  to pump  water from the  site's aquifers.   Upon
implementation, the extraction system will prevent migration of the contaminant
plume from FMC and BNR lands.  Extracted ground water will  flow to a publicly-
owned treatment facility.  The effectiveness of this  pump-and-treat system will
be assessed  through  monitoring of receptors, ground-water  levels,  contaminant
concentrations, and rates of discharge.

     EPA believes that this alternative  approach  for the ground-water operable
unit will provide a  permanent  solution to contamination at the  FMC  site.   The
operable unit deals  strictly with the  FMC and BNR lands and is expected to serve
as a permanent remedy for contaminated ground water in  these areas.   EPA also
believes that  the remedy's  expected attainment of State and  Federal ARARs and
its monitoring phase will ensure long-term effectiveness in  protecting public
health and the environment.
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                    NEW BRIGHTON/ARDEN HILLS/ST. ANTHONY SITE
                          ST. ANTHONY OPERABLE UNIT
                            ST. ANTHONY, MINNESOTA


HRS Score: 59.16                                                      NPL Rank: 39

Background

     The New Brighton/Arden Hills/St.  Anthony site is  located  immediately north
of Minneapolis  and St.  Paul,  Minnesota,  in  the  adjacent  communities  of New
Brighton, Arden  Hills,  and  St.  Anthony.   The  site consists of  more  than  18
square  miles of  ground water  contaminated  with volatile  organic compounds
(VOCs) .

     Approximately 75 to 80  percent of all Twin City  communities  that use ground
water for drinking  water receive it from the Prairie du Chien-Jordan aquifer
system.   In  June 1981,  the Minnesota Pollution Control  Agency  (MPCA)  and the
Minnesota  Department  of  Health  (MDH)  detected  volatile  organic  solvent
contamination in  the  Prairie du  Chien/Jordan aquifer system used for drinking
water in New Brighton.   The nearby City of St.  Anthony subsequently detected VOC
contamination in  its three Prairie du Chien/Jordan  aquifer wells.

     In  cooperation  with  EPA,  the   State  conducted  a  preliminary  Remedial
Investigation  (RI)  of  the   site  in   1983.    Because  the RI  did not  provide
sufficient information on the contamination in the  St. Anthony area, a further
RI  is  being  conducted.   To  provide  sources  of  drinking water  for  affected
residents in St.  Anthony until  the  final remedial  response  is selected, EPA
completed a  Phased Feasibility  Study (PFS).    The  resulting ROD for  the St.
Anthony operable unit was signed March 31, 1987.  The final response  action will
be recommended in a subsequent ROD when the RI/FS is completed.

     Federal  and  State  enforcement  activities   identified  more  than  ten
potentially  responsible  parties  (PRPs)  that  conducted some  activity at either
of the two major  source  areas: the Twin Cities Army Ammunition Plant  (TCAAP) and
a  petroleum  refinery.   However,  because  none  of the  PRPs  was  willing  to
participate  at that time, EPA and MPCA  proceeded with funding and undertaking
of remedial  activities.

Description of Site Work

     In  1983, the MPCA and EPA entered into a State lead  cooperative agreement
for  conducting  the RI  to  determine   the  extent and  source  of  contamination.
Trichloroethylene  (TCE) ,  the most prevalent VOC,  was  used  as  the indicator
chemical.  Preliminary  results of the RI  indicated  two plumes of contaminated
ground water  in the site area.

     The source  of  the  plumes appeared  to be several areas  in the vicinity  of
the TCAAP.  In wells  in both New Brighton and St. Anthony,  levels  of TCE exceeded
EPA proposed Maximum Contaminant Level (MCL)  for the protection  of human health
from contaminants in drinking water.  In response to  the  contamination, the City
of New  Brighton  closed  down its  six  Prairie du Chien-Jordan aquifer wells and
tapped  into  a deeper aquifer.


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     The RI provided  little  information on the extent of contamination  in  the
plumes in the St. Anthony  area.   To provide more information on the extent of
the contamination, EPA and the State initiated a subsequent RI/FS.   The MPCA is
planning to complete  the remaining tasks of the comprehensive RI  in 1988-1989
in order to  evaluate potential final remedial actions.  The U.S.  Army, the owner
of TCAAP, has agreed in a Federal Facilities Agreement to do a comprehensive FS
for the  entire  site  area upon completion of the EPA  and  State  RI.   The U.S.
Army,  however, does not feel  at  this time  that  there  is  sufficient information
to place responsibility for the  St. Anthony area contamination on  the TCAAP.

     While the RI was  being completed,  several initial remedial measures  (IRMs)
were taken to provide drinking water for  affected residents.  The  EPA lead  IRM
in 1983 involved installing granular activated carbon  (GAG) filters in two wells
in New Brighton.  The  State carried out an IRM to connect private well users in
New Brighton to water  mains.   In  1984, the State conducted an IRM to temporarily
connect St.  Anthony's water supply  to the  City  of Roseville.

Description of Feasibility Study

     The primary objective of the  St. Anthony operable unit  PFS was  to provide
safe,  potable water to consumers  who were dependent upon St.  Anthony's municipal
wells.   The  PFS addressed separately the  two  primary municipal wells and  the
emergency/standby well.   For the  two municipal wells,  three  alternatives  passed
the initial screening:

     (1)  Connecting the St.  Anthony wells to the Roseville/St. Paul
          system;

     (2)  Treating wells using air  stripping process;  and

     (3)  Treating wells using GAG  adsorption.

Similar alternatives were developed for the emergency/standby well.

     The alternatives were initially proposed  before  the  passage of SARA  and
were subsequently reevaluated. Under CERCLA,  the remedy  must attain applicable
or relevant and appropriate requirements  (ARARs).   Primary ARARs for this site
were the MCLs  set under the  Safe  Drinking Water Act  (SDWA).  The PFS assumed
that certain MCLs, which only were proposed when the study was completed,  would
be final by June 1987.

     Community response was considered a primary criterion in determining which
of the three alternatives  to  recommend.   The EPA presented results of the  PFS
at  a   public  meeting  and  recommended  construction  of  GAG water treatment
facilities.   Following public comment, the recommended alternative was amended
to include the construction of a  pipeline connecting the  emergency/standby well
to the treatment facility.
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Description of Selected Remedy

     The selected remedy (Alternative 3) consisted  of treating two of  the  St.
Anthony wells at a centralized  location using GAG adsorption, and constructing
a transmission line  from the emergency well  to  the  proposed central  treatment
facility.  This  remedy is the most cost-effective alternative and is expected
to  significantly and  permanently  reduce the  volume  of  the  contaminants  of
concern.  Additionally,  this alternative  is expected to attain the ARARs at  the
site.   To the extent  practicable,  the operable unit will  contribute  to  the
efficient performance  of any long-term remedial actions.
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                  NEW BRIGHTON/ARDEN HILLS/ST. ANTHONY SITE
               TWIN CITIES ARMY AMMUNITION PLANT OPERABLE UNIT
                           NEW BRIGHTON, MINNESOTA

HRS Score: 59.16                                                       NPL Rank: 39

Background

     The New Brighton/Arden Hills/St. Anthony site is  located  in Ramsey County,
Minnesota, north of Minneapolis  and  St.  Paul.   The site consists of more than
18 square  miles  of ground water  contaminated  with volatile organic compounds
(VOCs).    The  Twin Cities  Army Ammunition  Plant  (TCAAP)  is located  at the
northern edge of the NPL  site.

     In June  1981,  the  Minnesota  Pollution  Control  Agency (MPCA)  and the
Minnesota  Department  of Health  (MDH)  detected  volatile  organic  solvent
contamination in the Prairie du Chien/Jordan aquifer  system.  Approximately  75
to 80 percent  of all Twin City communities  that use ground water for drinking
water receive  it  from  the Prairie du Chien/Jordan  aquifer system.   The  State
conducted  several  initial remedial measures to provide drinking water to the
affected communities and  private well users.

     In 1983,  in  cooperation  with  EPA,  the  State  conducted  a preliminary
Remedial Investigation (RI) of the site.  For the  purpose of providing drinking
water to  different communities, the site was  separated into  several operable
units.  A  ROD  for  the  fourth operable  unit  was signed  in June 1986 to provide
New Brighton with an additional deep  well.  The ROD for the fifth  operable unit
was  signed in March  1987 to  provide  carbon  treatment for two  wells  in St.
Anthony.

     Federal and State  enforcement activities  identified the  TCAAP as a  major
source of  VOC  contamination in both the  Hillside  Sand Aquifer  and the deeper
Prairie du Chien/Jordan Aquifer.  Preventing migration of the VOC  contamination
plume was  designated as the sixth operable unit of the site.   In June 1987, the
U.S.  Army  submitted its  final  proposal  for  construction of a gradient control
system to  intercept the contamination plume.  The EPA concurred with this remedy
in a ROD signed on September 25, 1987.  Independent of  this operable unit, the
U.S.  Army, EPA, and MPCA  entered into a Federal Facilities Agreement.

     The plume interception system is an interim  remedial action.   The  MPCA,
will  complete  an RI for the  portion  of the  site  outside of the  Army  plant
boundaries  that  was originally started  in 1983  with  funding  provided  by  a
Cooperative Agreement between  EPA  and MPCA.   The Army will conduct the on-site
TCAAP RI   and  area-wide  (on-  and off-plant)  Feasibility  Study  (FS).   Upon
completion of the RI/FS,  EPA will  evaluate potential  final remedial actions  in
accordance with section 120 of CERCLA.

Description of Site Work

     The ongoing RI  conducted by  EPA  and MPCA and subsequent  investigations
indicated  the  TCAAP as a primary  source  of  contamination.  The  U.S.  Army has
estimated that approximately 26 pounds per day of VOCs were migrating from  TCAAP
into  the   ground  water   of  the  Hillside  Sand  aquifer  and the Prairie   du

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Chien/Jordan aquifer.   Monitoring  wells downgradient from the  site  showed VOC
levels in  excess of 40 ppm.   The  current MPCA study cannot determine  if the
plume of contamination  extended beyond the New Brighton municipal well  to the
nearby city wells of St. Anthony.   The  pathway of  greatest concern was through
ingestion of drinking water.

Description of Feasibility Study

     The U.S.  Army  document  Ground-water Remedial Action Alternative Analysis  considered
three alternatives for  preventing migration of contamination:

          (1)  Source removal and  no  action  for  the migrating
               contaminated water;

          (2)  Mechanical   barriers    --   source   control   and
               containment  slurry  walls,  pumping  wells,   and
               capping; and

          (3)  Ground-water extraction system  (referred to as  the
               Boundary  Ground-water   Recovery    System)
               hydraulic barriers with or without  source  removal
               and control.

     The ROD does not provide  details of the screening criteria used to evaluate
these alternatives.   Action-specific  and  contaminant-specific applicable  or
relevant and appropriate requirements  (ARARs) pertinent  to the  selected remedy
are discussed below.

     EPA received numerous written and oral comments during the  comment period.
The primary concerns expressed at  a  public meeting were the delay in cleaning
up the site, the possible health impacts,  and  the  fact that the  selected remedy
is not a final  solution.   The public believed that the U.S. Army attempted to
conceal the problem and avoid responsibility.

Description of Selected Remedy

     EPA decided  (and the  U.S. Army  concurred) upon  the Boundary Ground-water
Recovery System  (Alternative  3)  as the interim remedy.   Ground water will be
pumped from six previous Army-constructed wells,  treated by  air stripping, and
reinjected  into  the  aquifer via  an infiltration  basin.   Water treated  at the
treatment facility is expected to meet Federal and State  standards  for drinking
water, e.g., a cumulative risk-based criteria  of 10"6 for carcinogens.  The Army
estimates that the system will stop 90 percent of  the migrating VOCs.  Based on
information gathered during the first 90 days  of pumping, EPA will  determine if
the existing well system is adequate for  the  protection  of the  aquifer.

     The selected alternative is protective  of human health and the environment,
but,  because  it  does  not address  the source of contamination, it  is  not  a
permanent  remedy, it does not reduce mobility,   volume,  or  toxicity  of the
hazardous  constituents,  and it does  not use treatment  to the maximum  extent
practicable.    The  interim  remedy  is,  however,   expected  to  attain  ARARs.
Contaminant-specific ARARs for operation  of the air stripper include the Clean
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Air  Act  (CAA)  National  Ambient Air  Quality  Standards  (NAAQS)  and  National
Emission  Standards for Hazardous  Air  Pollutants  (NESHAPS),  and Minnesota Air
Emission Rules 7001.1210, 7001.1212. ARARs pertinent to treatment and discharge
of ground water  include  the Safe Drinking Water Act  (SDWA) Maximum Contaminant
Levels  (MCLs).
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                        INDUSTRIAL EXCESS LANDFILL SITE
                    ALTERNATE WATER SUPPLY OPERABLE UNIT
                               UNIONTOWN, OHIO

HRS Score: 51.13                                                     NPL Rank: 164

Background

     The Industrial Excess Landfill (IEL) site is a closed sanitary landfill  in
the unincorporated town of  Uniontown in northeastern Ohio.  Although  the  site
currently has a soil cover and vegetation,  solid waste material  is believed  to
lie under approximately 80 percent of the site.  There  are over 400 residential
homes located within a  1/2 mile radius  of the  site.

     From 1968 to 1980, the site was operated as a landfill for the disposal  of
municipal, commercial,  industrial, and chemical wastes.  In 1980, due to  public
concern and the fact that the landfill  was  reaching  its  capacity,  the  landfill
was closed  and covered.   Complaints by residents  prompted investigations  of
ground-water  contamination  because private wells were  the source of  drinking
water for nearby residents.

     In  October  1984,   the  site  was  included  on the NPL.    The  remedial
investigation/feasibility study  (RI/FS) was initiated  in December  1984.  EPA
implemented interim emergency actions and conducted a Focused Feasibility Study
(FFS) in August 1987 for the provision of safe drinking water.   The ROD for the
alternative water supply operable  unit was  signed September 30, 1987.   EPA  is
continuing to develop a comprehensive RI/FS  for a cleanup of the site,  In April
1985, notice  letters  were sent  to potentially responsible parties (PRPs), the
owner/operator  of  IEL and several  tire companies who  were  generators  of the
wastes.  Negotiations did not produce a settlement and  EPA took the lead in the
cleanup.  After the  FFS was released for public comments, EPA  issued special
notice letters  to PRPs  concerning  the implementation of  the  FFS.

Description of Site Work

     The  EPA  lead  RI   indicated  that  some  of the  residential  wells  were
contaminated  with organic  substances  (vinyl  chloride  and  chloroethane) and
inorganic  contaminants   (barium,   copper,   cadmium,   and nickel)   that  were
attributable  to the  landfill.   In  addition,  organic and  inorganic  substances
were  detected  in  the  shallow  wells near  the border  of the site.   A  risk
assessment concluded  that short-term  and long-term  consumption of  ground water
from contaminated residential wells may result in unacceptable health  risks.

Description of Feasibility Study

     Following  emergency actions  at  the site,  EPA  initiated an FFS in  August
1987.  The major objective of the  FFS was to provide a  supply  of safe  drinking
water to residents whose ground water was contaminated or has the potential for
being contaminated.   Four of eleven  alternatives  passed an initial screening
based on effectiveness,  implementability, and  cost:

          (1)   No action;
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          (2)  Construction of a new community well supply "into
               the Pottsville Group aquifers upgradient from the
               site;

          (3)  Connection to the Village of Lakemore water system;  and

          (4)  Connection  to the  City of  North  Canton water
               system.

     Alternatives were evaluated based  on their ability to protect public health
and  the  environment  and   to  meet  applicable  or  relevant  and  appropriate
requirements  (ARARs).   ARARs for  drinking  water were  identified as the  Safe
Drinking Water Act (SDWA) Maximum Contaminant Levels (MCLs),  Maximum Contaminant
Level Goals  (MCLGs),  and Ambient  Water Quality  Criteria (AWQC)  adjusted  for
drinking water for vinyl chloride.   For arsenic contamination, the  ARARs  were
MCLs and the AWQC.  For barium in the  drinking water,  the ARARs included MCLs,
an Ohio  EPA standard,  and  MCLGs.    Because they involved  an alternate water
supply,  none of the alternatives  addressed reduction of the  toxicity, mobility,
or  persistence  of  contaminants.    The  four  alternatives  provide  long-term
effectiveness by replacing the water supply.

     Community involvement in the IEL site has been extensive.  For example,  200
to 300 residents,  the news  media,  and public  officials attended a  meeting  in
August 1987 following  the issuance  of  the  FFS.   Many of  the  comments received
during  the  public  comment  period were  requests  that  EPA expand the   area
receiving the alternate water supply, and that sources other than that specified
in the chosen remedy be considered.

Description of Recommended Remedy

     The recommended remedy (Alternative 3)  was  the  connection of  approximately
100 homes to an alternate water supply,  specifically, to the Village of Lakemore
water system.  The chosen  remedial action  is  cost-effective,  is a  permanent
remedy,  and is expected to  meet  the ARARs  identified; however, due  to  citizen
concerns regarding water quality and capacity,  EPA has deferred the decision on
the alternate source of water.  EPA issued  a supplement to  the ROD  in December
1987, in  which the water  source  was  selected  to be  Country Club  Village  in
Summit County.
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                             LASKIN/POPLAR OIL SITE
                        SOURCE MATERIAL OPERABLE UNIT
                            ASHTABULA COUNTY, OHIO

HRS Score: 35.95                                                      NPL Rank: 492

Background

     The Laskin/Poplar Oil site is located west of the village of Jefferson  in
Ashtabula County, Ohio.   The 9-acre  site  is  bounded by Cemetery Creek and the
Ashtabula Fairgrounds.   The  site  was formerly used for a greenhouse  operation
beginning in the 1930s.  Boilers were installed to heat the greenhouses  in the
1950s, and tanks to hold waste oil for  burning were built in the 1960s.  When
the  greenhouse business  declined,  the  owner of  the site  began collecting,
reselling, and disposing of  waste  oils, much  of which  contained PCBs  and other
hazardous materials.

     The State of Ohio initiated action against the site owner in 1979 for air
and  water  pollution violations.   In  late 1980,  EPA evaluated  the  need for
remedial action  at  the site and in  1982  undertook  an emergency action,  which
included  removing  302,000  gallons  of  oil,  treating  430,000  gallons   of
contaminated water,  and solidifying  205,000  gallons  of  sludge.   Potentially
responsible parties (PRPs) removed another 250,000 gallons  of  oil wastewater  in
1985 and 1986.   EPA  issued an Administrative Order of Consent to 12 PRPs between
1984 and 1986, requiring their participation  in the remediation process.

     EPA divided remedial activities at the site into two  operable units  and  an
overall site investigation.   The first operable  unit  addressed the incineration
of  contaminated water  and  PCB-contaminated  oils.    The  ROD for  the  second
operable unit,  which  focused  on  source  material  that remained  on  site, was
signed  September 30,  1987.    The  overall site  investigation still  is  being
conducted and will address ground  water,  surface water, and soil contamination
as well as the extent of dioxin contamination.

Description of Site Work

     When the overall RI was  initiated,  the site contained 34 tanks, 4  pits, and
treatment and retention ponds.  Preliminary sampling indicated large amounts  of
seepage from tanks  and unlined pits into surrounding soils.   Investigations also
identified a threat  from contaminants leaching into ground and surface  water,
including Cemetery Creek, which runs into the Grand River,  a source of drinking
water for 25,000 residents.

     Potentially responsible parties, under Consent Order,  initiated  the study
for  the  second  operable  unit in  1985  to characterize  the remaining on-site
wastes.  Results indicated that waste materials  still present  at the site after
emergency  removal   actions  posed  a  serious  threat  to  human health and the
environment through the threat of  fire and exposure to PCBs.  Major contaminants
of concern at  the site are PCBs, polynuclear  aromatic  hydrocarbons (PAHs), and
volatile  organic  compounds  (VOCs),   all  of  which  were   present   in high
concentrations in waste  oil  and surrounding soils.
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Description of Feasibility Study

     The Phased Feasibility Study  (PFS) for the second operable unit  evaluated
remedial alternatives  for  the  removal of source materials,  including sludges,
waste oils, wastewaters, and contaminated soils (included in this  operable  unit
because they  were a source  of potential contamination of ground and  surface
water).   All attempts were made during  the PFS to ensure  that  the  alternatives
developed for this operable unit were consistent with final remediation for the
site.    Remedial  alternatives  developed,   in  addition  to  a   "no  action"
alternative, included:

           (1)  Solidification  of all  liquid wastes and disposal
               in licensed waste disposal facilities;

           (2)  On-site incineration of oils,  sludges, and soils,
               with off-site treatment  of wastewaters;

           (3)  Off-site incineration of oils,  sludges,  and soils
               and off-site treatment of wastewaters;  and

           (4)  On-site incineration of  oils,  sludges,  and soils
               that contained PCBs  at concentrations greater than
               25 parts per million (ppm) or halogenated organics
               at   concentrations   in   excess  of   500   ppm;
               landfilling of  the  remaining oils, sludges,  and
               soils; and off-site treatment  of wastewaters.

The PFS identified the Federal and State applicable  or relevant and appropriate
requirements  (ARARs)  that  the remedial action must  meet, consistent with  the
requirements of CERCLA.  One technology considered for use  on  the  site  was  on-
site containment of the wastes.  However, because  the Resource  Conservation and
Recovery Act  (RCRA)  land  disposal restrictions  were  considered ARARs,  this
option  was not  considered  further.    Other  ARARs  identified for  this  site
included RCRA thermal  destruction,  incinerator,  and off-site transportation
regulations;  Ohio Clean Air  Act  limits  on  incinerator  emissions;  and  Ohio
regulations for the off-site transportation of hazardous  waste.

     Public comment  on the  RI/FS  was  received  during  a public  availability-
session, a public meeting, and through written comments.  Residents  and local
officials supported the selected remedy discussed below.

Description of Selected Remedy

     The remedy  selected  was  on-site  incineration  of  all  oils,   sludges,   and
contaminated  soils   and   the  off-site   treatment   of  contaminated   waters
(Alternative  2).   This alternative  uses  a proven  technology (i.e.,  inciner-
ation),  and, because contaminated materials are destroyed it satisfies CERCLA1s
preference  for  permanent   solutions  and use  of  treatment  technologies.   The
remedy also does not involve  the off-site transportation of hazardous  materials
(i.e.,  the oils,  sludges,  and contaminated soils)  before  treatment;  when
implemented, it will provide a high level of protection of human health and the
environment.  The remedy is  also expected  to  meet all ARARs for  this  operable


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unit.  The  State  of Ohio was consulted  during the remedy selection process and
concurred with  the chosen alternative.
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                     NORTHERN ENGRAVING CORPORATION SITE
                               SPARTA, WISCONSIN

HRS Score: 38.75                                                      NPL Rank: 414

Background

     The Northern Engraving Company (NEC) site is located in Sparta,  Wisconsin,
23 miles east of LaCrosse, and  is bordered  on the  south  by  the  LaCrosse  River.
Areas of the  river's floodplain lie within the  site area,  and a city well is
4,000 feet from the NEC site.   The site  includes a manufacturing  facility that
produces  metal  name  plates  and  dials  for  the   automobile  industry.    The
manufacturing  process  involves  metal  finishing  operations   that   include
anodizing, chemical etching,  and chromate conversion coating.  During the 1970s,
NEC discharged  rinse  water  to  the on-site sludge  lagoon  to  allow the  metal
hydroxides to settle,  and effluent from the lagoon  ran  along a drainage ditch
to the  LaCrosse  River.   By  1980,  2  to  4  feet  of metal hydroxide  sludge  had
accumulated  in the  lagoon.    On  several  occasions,  sludge was  removed  and
landfilled on site.   NEC  also  used a seepage pit  to dispose of rinses and dye
solutions.

     EPA investigations of the NEC site resulted in its placement  on the  NPL in
September  1983  and the identification  of  NEC as  the potentially  responsible
party  (PRP).    Under  a  Consent Order  with  EPA,  NEC  initiated  a  remedial
investigation/feasibility  study  (RI/FS)  in  September 1985.   EPA signed the ROD
September 28, 1987.

Description of Site Work

      The  RI  conducted  by NEC  identified  four separate  areas  as potential
sources  of  soil,  ground-water,  and  surface-water  contamination:    the  sludge
lagoon, seepage pit,  sludge  dump site,  and lagoon drainage ditch.   The  sludge
lagoon was contaminated primarily with metal hydroxides.  The drainage ditch had
elevated levels of fluoride, aluminum, chromium, and copper.  On  two occasions
the sludge dump, now backfilled,  received contaminated  sludge from  the  lagoon
which  totals  approximately 930  cubic yards.   Metal hydroxides  found  in  the
lagoon  are  evident  in the sludge dump.    Ground-water  monitoring within  and
downgradient from  the seepage pit detected trace  amounts of volatile organic
compounds  (VOCs) and elevated  amounts  of heavy metals.   However,  because no
wells were threatened by contamination and  the dilution  caused by  the  LaCrosse
River, ground-water  contamination  was considered to present no exposure risk.
The LaCrosse River water exhibited no contaminants at  concentrations exceeding
any surface-water criteria except for zinc  which was shown  to meet  the chronic
toxicity water quality criteria.  Thus, the  RI concluded that the site presented
few environmental  or public  health threats.   The  only  considerable potential
human health risks  were from direct contact  with  soils in the drainage ditch and
contaminated sludge in the  sludge lagoon, and possible ingestion  of contaminated
ground water.
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Description of Feasibility Study

     The FS for  the site,  conducted by NEC under EPA's supervision,  evaluated
remedies for each discrete waste unit.  Because  the site appeared  to  present
little endangerment to  the environment or public  health, the remedial action
objectives emphasized the  minimization of  long-term contact with  contaminated
soil and  the  prevention  of ingestion  of  the contaminated  water.   Potential
remedial alternatives were screened against  the  CERCLA criteria  of  long-term
effectiveness,   implementability,  and  cost,   and  consideration  was  given  to
treatment technologies that permanently reduce toxicity, mobility,  or volume of
the waste.

         following remedies proposed for each area passed the initial screening:

     (1)  Sludge Lagoon:
          •    No action;
          •    Capping  lagoon;
          •    Solidification of sludge and capping  of  lagoon;
          •    Excavation and off-site disposal of sludge  and pumping
               and treating of ground water;
          •    Excavation and off-site  disposal of sludge and soil and
               pumping  and treating of  ground  water;  and
          •    Excavation  and   off-site   disposal  of   sludge  arid
               monitoring of ground water.

     (2)  Drainage Ditch:
          •    No action;
          •    Access restriction through installation  of a  fence;
          •    Excavation  of contaminated  drainage  ditch soil and
               placement in sludge  lagoon; and
          •    Excavation of contaminated drainage ditch soil and  off-
               site disposal.

     (3)  Sludge Dump:
          •    No action;
          •    Capping  of dump site;
          •    Excavation of sludge for off-site disposal;  and
          •    Excavation  of  sludge and soil  for off-site  disposal;
               and
          •    Excavation  of sludge  and  solidification  in sludge
               lagoon.

     (4)  Seepage Pit:
          •    No action;
          •    Excavation of soil for off-site disposal;
          •    Access restrictions  and  ground-water  monitoring;  and
          •    Monitoring  excavation  of soil  for off-site  disposal,
               and pumping and treating of ground water.

     The  major  applicable  or relevant  and  appropriate  requirements  (ARARs)
identified for the NEC  site were Resource Conservation  and Recovery Act (RCRA)
closure and  post-closure  requirements,  the  Clean Water  Act (CWA),  Wisconsin
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State closure and post-closure requirements, and  State  Ground-Water  Protection
Laws.

     The NEC site generated little public  interest  since being  identified as  a
Superfund site.  The public made no comments on the RI/FS or  Consent Order and
no party expressed any  interest in holding a public meeting.

Description of Selected Remedy

     The selected remedy comprises three components:   source control,  migration
management,  and  operation and maintenance.   For  source control,  contaminated
materials from the drainage ditch and sludge dump will  be excavated  and  placed
in  the  sludge lagoon  for solidification.   After  solidification, the  sludge
lagoon will be provided with  a  RCRA cover and monitored  for proper  closure.
Deed restrictions and long-term monitoring will be  implemented  for the seepage
pit.  Migration management consists of monitoring contaminated water through the
application of  alternative concentration  limits  (ACLs) downgradient  from the
sludge lagoon  and the  seepage pit.   For  operation and maintenance,   the  cover
over  the  sludge  lagoon and  the seepage  pit  will routinely  be inspected and
monitored.    Semi-annual  ground-water  sampling  and  analyses   at  compliance
monitoring wells will also be conducted.

      The  statutory emphasis on  treatment  and  long-term  effectiveness is
fulfilled through  the  use of solidification.   The long-term effectiveness of
RCRA caps placed over  the sludge dump and seepage  pit  can be ensured only as
long  as  monitoring continues.    The  remedy  reduces  the  mobility of  the
contaminants,   but does  not  reduce  their  volume  or  toxicity.    The  selected
treatment is expected to attain ARARs.
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                              SCHMALZ DUMP SITE
                             SECOND OPERABLE UNIT
                              HARRISON, WISCONSIN

HRS Score: 48.92                                                      NPL Rank: 190

Background

     The Schmalz Dump site  is  located  on  the north shore of Lake Winnebago in
Harrison,  Wisconsin, 90 miles north of  Milwaukee.   The site consists  of  7 acres
of wetlands  that since 1968  were  used as  a waste dump  for  solid waste,  car
bodies, pulp chips,  and other materials.  Between 1972 and 1973,  Gerald Schmalz,
the former  owner of the  site,  accepted fly ash  and  bottom  ash from Menasha
Utility.  In 1978 and 1979, Schmalz accepted the demolition debris of  a building
owned by the  Allis-Chalmers Corporation.    EPA  suspects  that  these wastes are
sources of present contamination at the site.

     The Wisconsin  Department of Natural  Resources  (WDNR) and the  U.S. Army
Corps of Engineers conducted on-site soil  sampling in early 1979 and  found high
concentrations of PCBs  in  the area of the Allis-Chalmers debris,  as well  as lead
and chromium  throughout  the site.    In 1979, the  State  sued  Mr. Schmalz,  the
waste hauler,  and Allis-Chalmers for illegal PCB-disposal, but lost the case
because of lack of evidence.  Mr. Schmalz sold  the  dump to his  son in 1983.

     In September 1984,  the site was placed  on  the  NPL.   The EPA lead remedial
investigation/feasibility  study    (RI/FS)  was  initiated during  April 1985.
Because of the immediate health threat presented by the PCB-contaminated debris,
EPA and WDNR decided to  designate an operable unit specifically  to address this
contamination.   The ROD  for this operable  unit was signed in August 1985 and
called  for  removal  of  PCB-contaminated debris  and sediments.   The  RI/FS for
remediation of the rest of the site  has  progressed concurrently  with  the design
of the PCB contamination operable unit remedy.  The RI for  the  entire site was
completed in June 1987.   The FS report  was  finalized in August 1987 and  the ROD
signed September 30, 1987.

     Eight potentially responsible  parties (PRPs)  were identified for the site.
Notice letters were sent  and a negotiating meeting held  to discuss  the RI/FS,
but none of the parties committed to perform the  RI/FS.

Description of Site Work

     The objective of the RI for the entire  site  was  to characterize  the areas
of the  site that were not  addressed by the PCB-contamination  operable unit.
Results of the study indicated that lead and chromium were the  contaminants of
concern at  the site and that direct contact with surface and  subsurface soil
were the exposure pathways of greatest risk.  PCB contamination is confined to
the area in which demolition debris was disposed;  EPA addressed this  threat by
removing the debris during the PCB-contamination operable  unit remedial  action.

     Although  traces of chromium were  found in ground water beneath  the site,
EPA determined that this contamination did not  pose a  health  threat because
levels  were  below Safe Drinking Water Act  (SDWA)  Maximum Contaminant  Levels
(MCLs).   Test  results  indicated  that leaching  of  soils was  not  likely to

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increase chromium and lead concentrations in the ground water to levels  greater
than MCLs.   However,  the remote possibility  exists  that  this pathway  could
become a concern at a later time.

Description of Feasibility Study

     The objectives  of the FS  for  the rest of the site were to protect  the
public  from  direct  contact  with  contaminated  soils,  and  to  monitor  for
degradation  of  ground-water quality from  those soils.   The FS developed  the
following  six alternatives  to meet  these objectives, all of which met  initial
screening  criteria and were retained for detailed analysis:

           (1)  Ground-water extraction; treatment of ground water with
               coagulation/flocculation, filtration  and ion  exchange
               to  reduce  contamination to  background  levels; and
               discharge  of the  treated ground  water  to  a  nearby
               stream;

           (2)  Construction of  a slurry wall;  placement of a  soil,
               gravel, and clay cap; and ground-water  monitoring;

           (3)  Construction of  a  Resource  Conservation  and  Recovery
               Act (RCRA) Subtitle C compliant  cap,  and ground-water
               monitoring;

           (4)  Construction of  a  low-permeability  soil cover, and
               ground-water monitoring;

           (5)  Excavation     of    contaminated     soil,
               solidification/stabilization   of   the   soil,   and
               replacement with treated soil; and

           (6)  No action.

     The following Federal applicable or relevant and  appropriate requirements
(ARARs) were identified:   SDWA MCLs; Clean Water Act (CWA) Ambient Water  Quality
Standards;   Water Quality  Act  of  1987  Great  Lakes  Protection requirements;
Executive Orders for Protection of Wetlands  and  Floodplain Management; and RCRA
clean closure and landfill closure requirements.  State  ARARs  included  ground-
water protection, shoreland management, and closure  requirements.

     During  the  public  comment  period, a local water-quality planning agency
and  one  private  citizen  expressed  support  for  the RCRA  compliant  cap
alternative.  The community does not perceive the site  as an immediate  danger,
although some residents are concerned about the potential for  contamination of
the Appleton water supply.  The State  expressed support for alternatives that
involve capping of the site, but was concerned that the cap would not adequately
be  protected from  damage.    The  State will  attempt  to  obtain  a  voluntary
agreement  from the landowner not  to damage  the  cap once it is  installed.   The
State  is aware  that EPA has  the  legal authority  to order further corrective
action should the owner attempt to damage the cap.
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Description of Selected Remedy

     The remedy selected for the Schmalz Dump site (Alternative 4) included the
following  actions:    installation  of  a low-permeability soil  cap  over  the
contaminated  soil;  implementation of  a ground-water monitoring  program and a
voluntary  well  abandonment program  for residents;  and a  recommendation that
adjacent property be analyzed  for  contamination.

     The selected remedy is the most cost-effective alternative,  is expected to
attain  ARARs,  and  adequately  protects human  health and the environment  by
eliminating the  threat  of  direct contact with  contaminated  soils.   The remedy
does not  reduce  the toxicity  of lead  and chromium  in soils or  in  the ground
water,  and provides minimal protection for  ground water.   It  will  reduce the
mobility of contaminants in soil,  however,  and provide long-term protection of
soil.
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                             BAYOU BONFOUCA SITE
                       SOIL CONTAMINATION OPERABLE UNIT
                               SLIDELL, LOUISIANA


HRS Score:  29.78                                                     NPL Rank: 731

Background

     The  Bayou  Bonfouca  site  is  located  about   7  miles   north   of   Lake
Pontchartrain in Slidell,  Louisiana,  and has an area of  about 55 acres.  The
site is an abandoned and dismantled creosote works that is  within the designated
100-year  flood  plain  of  the  bayou.    Land  use  to  the  east  of  the  site  is
primarily commercial,  and  to the southwest across  the bayou is a residential
subdivision.

     From 1892 to 1970,  the facility was operated under the ownership of various
creosote companies, and is  currently owned by the Braselman Corporation. During
its operating history, the facility has had numerous  releases of creosote.  The
primary contaminants are polynuclear aromatic  hydrocarbons (PAH) that have  been
found in the soils, surface-water deposits, ground water,  and bayou and channel
sediments.

     Numerous studies have been conducted to identify  and determine the extent
of contamination  at the site.   An  initial investigation in 1976  by  the  U.S.
Coast Guard was followed by a 1978 study conducted by EPA, the  Coast Guard, and
the  National  Oceanic  and   Atmospheric   Administration.    Two  potentially
responsible parties  (PRPs) were identified:  American Creosote  Works,  the  last
wood  treating company  to  operate  the site,  and Braselman Corporation,  the
present owner.   In  1981,  the  State of Louisiana  rejected a cleanup  proposal
proposed  by  Braselman Corporation, and the  site  was included  on  the NPL  in
December 1982.

     In 1983, EPA  initiated  a phased  remedial investigation/feasibility study
(RI/FS) for  Bayou  Bonfouca.   The  first phase  identified  and estimated the
surface contaminants which resulted  in  a focused feasibility study (FFS).  Based
on the FFS,  a record of  decision  (ROD) was signed in August 1985 for the removal
and offsite disposal of contaminated materials.  Due  to further  studies in the
second phase  and  changes  in CERCLA as  amended by  SARA,   off-site disposal was
never implemented.   A new  ROD  for  the  Bayou  Bonfouca site was issued  in March
1987 as detailed in the following paragraphs.  The  final remedial investigation
report and feasibility reports  were issued in April and June 1986, respectively.

Description of Site Work

     The  remedial  investigations have  identified  that the contaminated areas
include a major portion  of  the  south half  of the  site,  Bayou  and channel
sediments, and  the  surficial  and shallow artesian  aquifers.   These studies
indicate  that  Bayou and  channel  contaminated  sediments  are estimated  at
approximately 47,000 cubic yards.
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Description of Feasibility Study

     The June 1986 FS  identified  remedial  alternatives necessary to reduce or
eliminate the potential  for  ingestion of  carcinogens in ground water, surface
soils, and  shellfish;  to  control the  migration  of PAH  contamination in the
aquifer;  and  to reduce  or eliminate the  direct  contact  threat  posed by the
sediments and surficial waste.

     After  a  final  screening  of  alternatives,  a  total  of  nine  treatment
alternatives for source control were considered:

          (1)   No action;

          (2)   Permanent   diversion   of  the  bayou  with  in-place
               stabilization of bayou sediments with backfill and cap,
               on-site landfill of creosote waste piles, and on-site
               cap of soil;

          (3)   Bayou partition and on-site  landfill  of  sediments,  on-
               site landfill of creosote waste piles, and on-site soil
               cap;

          (4)   Alternative 3 with off-site landfill of  sediments  and
               waste piles;

          (5)   Bayou partition and on-site incineration of  sediment,
               waste piles, and soil;

          (6)   Alternative 5 using a soil cap instead of incinerating
               contaminated soil;

          (7)   Bayou partition and on-site  biological treatment of
               sediment, waste piles, and  soil;

          (8)   Bayou partition and off-site  landfarming of  sediment,
               waste piles, and soil; and

          (9)   Bayou partition and off-site incineration of sediment,
               waste piles, and soil.

The  eight  remedial  action   alternatives   included   identical   measures  for
remediating ground-water contamination  through use  of slurry walls around the
site.

     In July 1986, a public  meeting was held in which  citizens requested a 3-
month extension  of  the public comment  period  until  October 31,  1986.  During
this time SARA was signed  and the proposed remedy for  the  site did not comply
with  the  provisions  of  the  Act.    Under  CERCLA  as  amended,  consideration of
alternatives must  demonstrate a  preference  for  permanent  solutions,  and all
remedial action must attain applicable or relevant and  appropriate requirements
(ARARs).  Several of the remedies  considered in the  June 1986  FS were permanent
solutions.   The relevant  ARARs  identified  and  considered included Executive
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Orders 11988 and 11990 for Floodplain Management and Protection of Wetlands, the
Clean Water Act  (CWA), and the  Resource Conservation and Recovery Act (RCRA).

Description of Selected Remedy

     The alternative  recommended for  the Bayou Bonfouca  site (Alternative  6)
includes on-site  incineration of the creosote  waste deposits and contaminated
sediments  in a mobile  incinerator.   The incinerator ash and contaminated soils
will be covered with  a RCRA cap.    Ground  water will be  remediated through a
pump-treat reinjection process.

     This alternative  is  considered protective and cost-effective,  is expected
to attain ARARs, and uses permanent solutions and treatment technologies to the
maximum extent practicable.  The Louisiana  Department of Environmental Quality
concurred with this remedy.
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                               CLEVE REBER SITE
                          ASCENSION PARISH, LOUISIANA


HRS Score: 48.80                                                     NPL Rank: 196

Background

     The Cleve Reber site  is located in Ascension Parish,  Louisiana, between New
Orleans  and  Baton Rouge.   The  25-acre  site is  bounded by  swamps  and  semi-
developed agricultural and residential areas.  Originally used as  a borrow pit,
the site later became a  disposal area for municipal and industrial  waste between
1970  and 1974.   Environmental  Controls  Company  (ECC) ,  with Cleve  Reber as
president, leased  the property and operated a  landfill  before abandoning the
site in 1974.

     After  numerous  site  inspections  and sampling  efforts,  the   State of
Louisiana declared the area an abandoned hazardous waste  site  in  October  1979.
Information provided  by potentially  responsible parties  (PRPs) suggested that
6,400 drums of waste  were buried on  site.   In response to public concern, EPA
conducted an emergency removal of 1,100 surface barrels and waste piles in  1983.

     An EPA  lead remedial investigation (RI) completed  in May 1985  indicated
that the major concern is  the  Norco Aquifer, a surface-flowing  artesian aquifer
that supplies  fresh  water to industrial and private consumers.   Ground-water
samples collected  in early June 1985 provided  additional data for evaluating
remedial   response.     Due   to  lack   of  data,   a   supplemental  remedial
investigation/feasibility study (RI/FS) was completed in September 1986,  and the
ROD was signed March  31,  1987.

     EPA has since issued notice letters to ECC, former owners of the property
and known generators of  the  hazardous waste.   Several  PRPs  that identified
themselves  as waste  generators  participated  in the  emergency  removal and
expressed interest in participating in remedial actions.

Description of Site Work

     Results  of  the  initial  RI  indicated that  industrial  waste,  consisting
partly of hazardous organic compounds, has migrated and mixed with  the municipal
waste.  Significant  soil  contamination has been detected on site, and studies
of ground water in the shallow sand layer beneath the  site found elevated levels
of hexachlorobenzene (HCB),  hexachloroethane   (HCE),  and hexachlorobutadiene
(HCBD).    Because  the  contamination was  detected in the shallow sand  layer, an
additional RI/FS was undertaken to investigate ground-water contamination.

     The primary hazards  to human health were  associated with ingestion  of or
direct contact with surface soils,  on-site  surface water,  on-site  leachate, and
ground water.  The RI found no  contamination  in the  deep sand layer or in the
Norco Aquifer, and contamination appeared  to be confined  to the site.
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Description of Feasibility Study

     The initial  FS  was completed in May 1985,  and the  supplemental  RI/FS was
completed  in  September 1986.   Although the  original  and supplemental  RI/FSs
predated SARA,  efforts  were made  to conform  the supplemental  study  to  the
anticipated  statutory  requirements  for  selecting  permanent  solutions  and
treatment technologies  to  the maximum extent  practicable.

     Based on the criteria of effectiveness, implementability, cost, and ability
to  meet applicable  or  relevant  and appropriate requirements  (ARARs),  the
following remedial alternatives were  considered:

           (1)  No action;

           (2)  Complete removal of all contaminated material with
               disposal  in an off-site landfill;

           (3)  Closure  of  the   site  with  containment  of  all
               contamination;

           (4)  Alternative  3   with  on-site   incineration   or
               disposition of all bulk sludges  and materials  in
               drums;

           (5)  Alternative 3 with off-site  incineration;

           (6)  Alternative 2 with off-site  incineration;  and

           (7)  Alternative 2 with on-site  incineration.

     ARARs identified in the supplemental FS included the Clean Water Act (CWA),
the  Resource  Conservation  and  Recovery   Act   (RCRA),  Executive  Orders  for
Floodplain Management and  Protection  of  Wetlands,  and  State  laws.   At the time
the ROD was  signed,  the  State  had not  identified any ARARs other than those
identified by EPA.

     EPA issued  a press release  on May  31,  1985,  that described the  site  and
discussed EPA's proposed remedy.   At  that  time,  the proposed  remedy was  a cap-
in-place approach.    Sampling  results  subsequently  released  prompted  EPA  to
postpone a decision  on the  remedy  and commence a  supplemental  RI.    After
identifying its preferred  alternative (discussed below),  EPA  conducted another
public meeting  in February 1987.  Most  people attending favored the selected
remedy.

Description of Selected Remedy

     EPA recommended Alternative 4 as the approach for remediation of  the Cleve
Reber site.  Alternative 4 involves the  on-site incineration  of drummed  wastes
and bulk sludges,  the  removal  and backfilling  of  all  ponds,  and the use  of  a
RCRA cap over remaining contamination.  The cap will  cover only the  area of the
site used for disposal of  industrial  or  hazardous  waste.  The  alternative will
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involve removal  of  the  source of ground-water contamination,  thereby reducing
the future volume and mobility of the contaminants.

     Residual contamination after the source  removal  will be attenuated by the
underlying organic  clays.   The  site  will be monitored  for 30 years  to guard
against the  migration  of contaminants.   The  alternative chosen  is adequately
protective, cost-effective, is expected to comply with ARARs, and uses permanent
solutions and treatment technologies  to  the maximum extent  practicable.

Description of Remedial Design

     In September 1987,  EPA and  the contractor began the remedial design.   In
February 1988,  field work to gather additional information for the design began.
Trenching was performed to identify specific locations of buried drums and bulk
sludges.  Leachate, pond water,  and waste were sampled  for  additional testing.
Design specifications and  contract  documents  are scheduled  to  be completed by
the spring of 1989.
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                       COMPASS INDUSTRIES LANDFILL SITE
                             WEST TULSA, OKLAHOMA

HRS Score: 36.57                                                      NPL Rank: 483

Background

     The Compass  Industries Landfill site  is  located in West  Tulsa,  Oklahoma
near the communities of Berryhill and Sand Springs.  The site includes a 32-acre
landfill area and  is  situated  on  a bluff approximately  200  feet above  the
Arkansas River.   Surface water  from precipitation runoff,  springs, and seeps
flows into  the  River from the bluff  through  a network of  small  streams.   The
site is  underlain by two aquifers,  neither of which  is  known to be  used  for
drinking water.

     The site was  initially used as a limestone quarry from  the  1930s through
the 1950s.   From 1972 to  1976,  the site  was  permitted by the Oklahoma State
Department  of  Health (OSDH) as  a municipal and industrial landfill,  although
there is evidence  that  dumping occurred at the site as early as  1964.   During
the 1970s,  several  fires were  reported at  the landfill.  Following  complaints
from  residents  about  air  emissions  from  the  fires,   the  State  and  EPA
investigated the site.   The  site was  listed on the NPL in September  1984.

     EPA provided funding for  a  State lead Remedial  Investigation (RI) in 1984
to  determine  the  extent  of  ground-  and  surface-water  contamination.    The
remedial investigation/feasibility  study (RI/FS) was  completed  in mid-1987  and
the  ROD was  signed September  29,  1987.    Investigations  have  identified
approximately 20 potentially responsible  parties  (PRPs),  but  there has been no
documented  involvement by PRPs in the remediation process.

Description of  Site Work

     The State  lead  RI  identified surface runoff to the  Arkansas  River as  the
most significant  pathway of exposure.   The RI identified 12 inorganic and 33
organic  pollutants  in the  two aquifers  beneath the  site  and in  surrounding
soils.    Although the upper  aquifer on the site  was highly contaminated,  the
hydrogeology and topography of  the site  appeared to have minimized the migration
of the contaminated ground water.

Description of  Feasibility Study

     The State  lead FS  developed an initial  set of  remedial  approaches  for
limiting surface-water  migration.   Six  alternatives  were  chosen for  a  full
evaluation  against the criteria  specified by CERCLA:

          (1)  No action;

          (2)  Capping and on-site  ground-water  treatment;

          (3)  Capping and off-site  ground-water treatment;

          (4)  Complete on-site thermal destruction of landfilled
               material;

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          (5)  Partial on-site thermal destruction of landfilled
               material and capping of soils; and

          (6)  Partial off-site thermal destruction of landfilled
               material and capping of soils.

     The  FS  also  identified  the  applicable   or  relevant  and  appropriate
requirements  (ARARs)   that  the  remedial  action must  meet.    Federal ARARs
identified for the site included Resource Conservation and Recovery Act (RCRA)
capping  requirements,  National  Pollution  Discharge  and Elimination  System
(NPDES)  requirements,   the  Clean  Water  Act  (CWA),   the Fish  and  Wildlife
Coordination Act  (FWCA),  and  the  Endangered Species  Act  (ESA).   State ARARs
identified  included the  Oklahoma  Clean  Air Act and Oklahoma  Water  Quality
Standards.

     There was substantial  public  involvement during the  RI/FS  process.  EPA
held  a public meeting on August  18, 1987,  to  explain  the remedy  that was
proposed (discussed below)  and to  answer questions from  the approximately 65
people in attendance.  EPA also  met  with officials  from Tulsa and the  City of
Sand Springs in order to explain the proposed remedy.

Description of Selected Remedy

     The remedy  proposed during the public  comment  period  and subsequently
selected was Alternative 2, a  cap constructed to meet the specifications of RCRA
closure requirements  and treatment of  the  upper, perched aquifer,  if  deemed
necessary following placement of the  cap.   Specifically,  the remedy consisted
of  site  grading, placement  of  a  cap over  contaminated soils,  diversion of
surface water  from  the site,  monitoring  of air  emissions in case of  further
fires, and installation of security fences and warning signs to restrict access
to the site.  EPA decided to defer treatment of the upper,  perched aquifer until
after  placement  of  the RCRA cap and  evaluation  of  the  cap's effectiveness in
restricting or eliminating the surface-water discharges along the bluff.

     This  remedy  is   expected  to be  protective  of  human health   and  the
environment  and  uses  permanent  solutions  and  treatment  technologies  to the
maximum extent practicable.   The remedy  is  also expected to  attain all  ARARs.
The State of Oklahoma was consulted during the FS, and concurred with the remedy
selected.
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                   SAND SPRINGS PETROCHEMICAL COMPLEX SITE
                        SOURCE CONTROL OPERABLE UNIT
                            SAND SPRINGS, OKLAHOMA

HRS Score:  28.86                                                     NPL Rank: 761

Background

     The Sand Springs site is located in an industrial complex on the northern
bank of the  Arkansas  River in Sand Springs, Oklahoma,  5  miles west of Tulsa.
The site is  the  former location of the Sinclair  oil refinery, which operated
from the turn of  the century until 1949.   The site  encompasses  approximately 235
acres and most of the property was conveyed to Sand  Springs Home in 1953 to be
developed into  an industrial area.  In 1969, the remaining 38-acre tract  of  land
at the site  was  put under  control  of  the  Atlantic Richfield  Company  (ARCO) in
a merger with Sinclair.

      Part of the site developed as an industrial area and was  used by  a  solvent
recycling facility  in the  late  1960s and  early  1970s.   During this  period,
hazardous substances were stored or disposed of in drums,  tanks, unlined pits,
and lagoons, or  buried on  site.   Sulfuric  acid  sludge pits from  the former
refining  operation   are  contaminated   with   heavy   metals  and   organics.
Construction activities exposing part  of one pit resulted  in a release of fumes
that necessitated evacuation  of  a  nearby  factory, during which several people
required medical  attention.   Other waste pits have  contaminated ground water
with  volatile  and  non-volatile  organics  and   chlorinated   solvents.    EPA
investigations in 1980 and 1982 revealed that lagoons and a surface impoundment
were also contaminated.  A total of approximately 130,000  cubic yards of waste
are present at the site.

     EPA proposed  the  site  for the NPL in  September 1983.   In June  1984, the
Oklahoma  State  Department  of Health  (OSDH)  agreed to conduct  the  remedial
investigation/feasibility study (RI/FS) using funds EPA provided.  In an  attempt
to address the most  apparent contamination quickly,  EPA  established a source
control operable unit to focus on waste in the pits, ponds, and lagoons.   OSDH
completed the source control operable  unit RI/FS in April  1987,  and the  ROD was
signed September 29,  1987.   The  remainder of the  site,  including ground-water
contamination,  was addressed In a final operable unit FS that was completed in
April 1988.   A public meeting was held March 24,   1988.  The proposed  remedy is
no action (monitoring  following  the source  control remedial action).   The ROD
is expected to be signed in June 1988.

     EPA has  identified approximately 300 potentially responsible parties (PRPs)
for the site, two of which have taken actions at  the site under administrative
orders.

Description of Site Work

     During its source control RI,  the OSDH sampled 11 waste disposal  locations
on the Sand  Springs  site.   Results indicated  that  all  surface locations  were
contaminated with  inorganic and organic  compounds.   The  priority pollutants
identified included lead,  zinc,  chromium,  chrysene,  phthalate, toluene, trans
1,2-dichloroethene,  and  tetrachloroethane.    The  source   control  RI   also


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identified three major risks to human health and the environment from the  site:
direct  contact  with wastes;  air emissions  from the  site;  and  surface-water
contamination due to runoff from the site during heavy rains.

Description of Feasibility Study

     In  order   to  mitigate   the   on-site   soil,   surface-  water,  and  air
contamination, the OSDH developed  five   remedial alternatives, in  addition to
the "no action" alternative:

          (1)  Excavation   and  on-site   thermal   destruction  of
               contaminated sludges and on-site disposal of  residual
               ash;

          (2)  Solidification of contaminated sludges and disposal in
               an on-site landfill;

          (3)  Excavation   and  on-site   neutralization,    solvent-
               extraction,  and treatment of  hazardous  sludges,  and
               disposal  of oil, water, and solid byproducts;

          (4)  Excavation  and off-site thermal  destruction of
               contaminated sludges; and

          (5)  Excavation  and off-site  solvent-extraction treatment
               of contaminated sludges.

Alternatives, which utilized  any on-site  disposal,  also included construction
of a RCRA cap over  the  landfill  area.   Each alternative also  included  removal
and treatment of contaminated liquids.

     The FS  identified  the following  applicable or  relevant  and  appropriate
requirements (ARARs) for the  site:  the Resource Conservation  and Recovery  Act
(RCRA); the Clean Air Act (CAA) National Ambient Air Quality  Standards (NAAQS);
National Pollutant Discharge Elimination System (NPDES)  requirements; the  Clean
Water Act (CWA); Executive  Order 11988  for Floodplains;  the Fish and Wildlife
Coordination Act; and State solid waste, hazardous  waste, clean air,  and  water
quality regulations.

     The  local  community  expressed concern about  the  construction  of   an
incinerator  on  site,   particularly  about  potential air  pollution  from  the
incinerator, potential decline in property values from its presence,  and whether
the incinerator  would be removed after  cleanup.   At least 180  people attended
the public  meeting  held to discuss  the source  control  RI/FS   results, during
which EPA agreed to extend the public comment period.
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Description of Selected Remedy

     After  detailed analysis  of the  alternatives,  EPA  proposed the  on-site
thermal destruction as the source control  alternative best satisfying statutory
criteria,  although  this  remedy was costly and  neither the State or  the  local
community preferred it.

     During the  public  comment period, ARCO, as  a  PRP,  made a proposal  for  a
privately financed remedy for  the site  that  did not  include  construction  of an
on-site incinerator.  EPA evaluated ARCO's proposal and decided  to  allow ARCO
to prove  its  effectiveness  during  the remedial design phase  of  the source
control operable unit.    However,  if the  design  of the  ARCO  remedy fails to
satisfy EPA criteria,  the ROD stated that  incineration will be  the remedy. The
ARCO proposal includes the following actions:

          •    Excavation and off-site thermal destruction of sludges
               in the waste oil  and solvent  lagoon areas;  and

          •    Solidification/stabilization  of  all remaining sludges
               in a manner meeting EPA criteria,  and  containment of
               the  resulting  matrix  in  a  cell  or  cells  to be
               constructed   on   site   in   compliance   with    RCRA
               requirements.

     Although ARCO's proposal  would reduce greatly the mobility  of wastes, the
toxicity of wastes would not be reduced and the volume of wastes  would actually
increase.   EPA is also  concerned about the lack of demonstrated  permanence of
the  solidification alternative.   Unlike  thermal  destruction, which  would
eliminate organic contaminants permanently, the capability of solidification or
stabilization techniques to contain high organic wastes securely and permanently
has not been demonstrated in the  pilot studies conducted on site.   However, ARCO
has  assured EPA that  if the  remedy  fails,  the  company  will  take  further
corrective action.  ARCO has   signed a  consent  decree to conduct the remedial
design  and  remedial action.    Remedial  design  is anticipated  to begin in the
summer of 1988.

     This remedy is expected to be technically feasible and to  meet ARARs. The
ARCO proposal initially would  cost less than thermal destruction,  and  the State,
local agencies,  and residents  support  it.
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                           CRYSTAL CITY AIRPORT SITE
                              CRYSTAL CITY, TEXAS


MRS Score: 3226                                                     NPL Rank: 639

Background

     The Crystal  City  Airport  site is located in Crystal City, Zavala County,
Texas,  approximately  100  miles southwest  of San  Antonio.   Several  private
companies conducted aerial pesticide  application businesses at the airport until
1982.   In response to concerns that  agricultural chemicals left by defunct aerial
operators presented a  threat to local residents,  the Texas  Department of Water
Resources conducted a preliminary investigation of the site.  The results of this
investigation, and of follow-up investigations,  indicated that surface soil was
highly contaminated with pesticides.

     In  October  1983,  EPA initiated an  immediate removal  action to  remove 40
yards of waste  and 50  to  70 drums of the most highly contaminated materials.
In a second removal action, initiated in May 1984, EPA transported 19  drums off
site for disposal, constructed a fence with a locked entrance  gate, and posted
warning signs.  A draft remedial investigation/feasibility study (RI/FS) for the
site was completed in  April 1987,  and the ROD was signed September  29,  1987.

     Five potentially responsible parties (PRPs),  including the City of Crystal
City,  have been  identified.   Four  PRPs  are no longer in business and the City
appears unable to finance  the cleanup.

Description of Site Work

     Following the immediate removal  actions, EPA  and the State of Texas entered
into a cooperative agreement in September 1985 to  perform an RI/FS at  the site.
A draft  RI report submitted in April 1987 identified 2 primary areas in which
surficial soil contamination was 1 to 3  feet deep.  A combined cleanup level of
100 mg/kg was  proposed  for the contaminants of greatest concern:  toxaphene, DDT,
and arsenic.   The RI  determined that  remedial action would be required to reduce
the potential  for  public  health  exposure  through  direct contact  with  and
ingestion of  contaminated  soils and  inhalation of contaminated dust particles.
The RI  indicated that  treatment for surface-water, ground-water,  and ambient-
air contamination would not be needed.

Description of Feasibility Study

     In  order to meet  the objectives of reducing soil contamination  levels to
100 mg/kg total pesticide (toxaphene, DDT, arsenic),  maintaining background air
quality levels,  and minimizing surface-water degradation, a number of potentially
applicable remedial  technologies were studied.   An initial screening based on
the  criteria  of  long-  and  short-term  environmental   and  health   effects,
implementability,  and  cost was   performed,  after  which  eight   alternatives
remained:

           (1)  No action;
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          (2)  In-place containment  of soils with an  8-acre,  9-inch
               asphalt cap;

          (3)  Consolidation  of wastes  and  capping  with  a  multi-
               layered cap;

          (4)  Containment of soil (without treatment)  in an off-site
               landfill;

          (5)  Solidification of  contaminated soil and placement  in
               an off-site landfill;

          (6)  On-site incineration  and soil  washing of contaminated
               soil;

          (7)  Placement of soil in  an off-site landfill; and

          (8)  Decontamination  of   soil   (soil  flushing)  through
               utilization of  a critical  pressure fluid extraction
               unit.

     The following applicable or relevant  and appropriate requirements  (ARARs)
for the site were  identified:   Clean Water Act (CWA)  water  quality  standards,
Clean Air Act  (CAA)  National Ambient Air  Quality Standards  (NAAQS),  the  Texas
Solid Waste Disposal Act, and the Texas Clean Air Act.

     Some community members attending the public meetings for the site expressed
support for incineration of the  contaminants.  Some commenters  alleged that the
proposed  remedy  (Alternative  3)  was  "substandard" and  did  not  meet CERCLA
statutory preferences  for  permanent remedies and treatment alternatives  that
significantly reduce the mobility, toxicity,  or volume  of the contaminants.  EPA
indicated,  however,   that  such   soil   treatment   alternatives   would   not
significantly  reduce  the  mobility of   the contaminants,   because  of  the
characteristics  of  the  contaminants and the  impermeable  nature of  the soils.
Although toxicity of organic contaminants could be reduced through an integrated
incineration system,  the  technology necessary to  remove  the  arsenic compound
from the soil does not exist.

Description of Selected Remedy

     The alternative recommended for  the site  includes on-site consolidation and
RCRA-approved capping of soil whose  contamination exceeds a combined total of
100 mg/kg toxaphene,  DDT, and arsenic (Alternative 3).  The proposed remedy will
minimize the forces  that  drive  the   transport of  waste from the site and  will
remove the direct contact threat.  Although the remedy selected does not  involve
permanent treatment, it is expected  to attain ARARs.
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                            HIGHLANDS ACID PIT SITE
                   GROUND-WATER REMEDIATION OPERABLE UNIT
                               HIGHLANDS, TEXAS


HRS Score:  37.77                                                      NPL Rank: 450

Background

     The Highlands Acid Pit  site  is located on a sparsely populated  area  1.4
miles west of Highlands, Texas.   Dense vegetation covers the site,  except  for
a bare area at the site center that  is  believed to be  the  primary dumping area.
The site was  used for the disposal of industrial waste  sludge,  protably sulfuric
acid from a  refinery  process,  during  the  early 1950s.   Organic  and  inorganic
constituents have been found in the site's shallow aquifer.

     In 1984, EPA signed a ROD addressing the  source of contamination  at  the
site.  The remedy called for  excavation and disposal of contaminated  soil  and
the  installation  of   a ground-water  monitoring  system.    The  ground-water
remediation phase is a separate operable unit,  for which an independent ROD  was
signed June 26,  1987.   The ground-water operable unit  is based  on the  remedial
investigation/feasibility  study (RI/FS)  conducted in  preparation  for  the 1984
ROD,  and on subsequent studies of ground-water contamination.

     Only one  potentially responsible party  (PRP),  the  landowner,  has been
identified.     This  PRP  lacks   the   resources  to  underwrite   ground-water
remediation,  and  attempts  to  locate generators of the waste have  failed.   EPA
therefore proposes to  use Fund  resources  for the  ground-water remediation
operable unit.

Description of Site Work

     Prior to  the 1984  ROD,  EPA  conducted  an RI/FS  to  assess wastes  in  the
hydrogeologic system.   This RI included information relevant to the ground-water
operable unit.  In November 1985,  EPA conducted a  further  ground-water study to
evaluate the potential for shallow contaminants to migrate  after the source  of
contamination was removed.

     Sampling results  revealed high concentrations of volatile organic compounds
(VOCs)  and  metals  in  the  shallow aquifer.    Contaminants  of major  concern
included benzene,  pyridine,  cadmium,  chromium, and lead.   No  contaminants  of
concern were detected in the middle aquifer.   Studies  of  the  ground-water flow
indicated that the contaminants will attenuate  to  nondetectable levels in about
350  years.   Inorganics  at the site  will settle  between  the  top and  middle
aquifers;  organics,  if  they  reach  the middle  aquifer, could  be detected  by
ground-water monitoring before levels  of concern are  reached.

Description of Feasibility Study

     A feasibility study (FS) for the  ground-water operable unit was completed
in 1986  to  eliminate  or reduce  the  risk of  future  exposure  to the  shallow
aquifer contamination.   EPA developed five remedial alternatives to be evaluated
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during the  FS,  and subsequently performed ground-water studies  to  provide  the
necessary data for the evaluation.  The following alternatives were  considered:

          (1)  Isolation of  the  upper  aquifer;

          (2)  Recovery and  off-site disposal;

          (3)  Recovery, biological treatment, and discharge/disposal;

          (4)  Recovery, carbon absorption,  and  discharge/disposal;
               and

          (5)  No action, with ground-  and surface-water  monitoring.

     As  required  by  CERCLA,   EPA considered   applicable   or   relevant   and
appropriate requirements (ARARs) in evaluating the alternatives.   Water Quality
Criteria (WQC) were  judged to be  ARARs for  contaminants  in  the  upper aquifer
because of the hydrogeologic connection to surface waters. Maximum  Contaminant
Level concentrations  (MCLs)  were determined to be ARARs  for  the  deeper ground
waters.

Description of Selected Remedy

     EPA recommended selection of  the  "no action"  alternative (Alternative  5),
which included  monitoring of the  surface environment and ground water.   EPA
determined that this alternative was consistent with legal requirements and  was
protective of public health  and the environment.   This judgment  rested on  the
finding  that although  organics  and  inorganics  are  present in the  shallow
aquifer, they have not  affected deeper ground water.  Once the  source removal
is  complete,  the  migration  of  contaminants to  the shallow  aquifer will be
reduced.  The natural flow of water will attenuate present  contaminants, leaving
the middle aquifer unaffected.

     Although CERCLA promotes  the selection of permanent remedies  that reduce
the toxicity,  mobility,  or  volume of  contaminants,  the  long- and short-term
effects of the preferred remedy  compare favorably  with the other  alternatives.
Because the ground-water recovery alternative would have exposed  area  residents
to the contaminants over a 7- to 9-year period,  it was eliminated as an option.
The 1986 Land Disposal Restrictions prevented the  selection of the  alternative
to recover and dispose of ground water.

     EPA and the Texas Water Commission participated in  a public meeting held
on May  12,  1987,  to discuss  the details of the  remedy.   Those  attending  the
meeting generally expressed  satisfaction with the  remedy.
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                       PETRO-CHEMICAL SYSTEMS INC., SITE
                       FRONTIER PARK ROAD OPERABLE UNIT
                                LIBERTY, TEXAS

HRS Score:  29.94                                                     NPL Rank: 728

Background

     The Petro-Chemical site is a 296-acre tract of  land  located in a sparsely
populated area south  of Liberty in southeastern Texas, approximately 40  miles
northeast of  Houston.   In the  northwest corner of the  site, unspecified  waste
oils were stored in several  pits.   In June 1970,  all  disposal operations were
discontinued.  Waste oils  also were spread on Frontier Park Road as a method of
dust control.  The road lies within the site boundary  and provides the primary
access to persons living  at  the site.   The site has been inhabited by as many
as 11 families since 1974, although only two  families remain as  of August  1986.

     Preliminary sampling performed by the Texas Water Commission (TWC) in 1982
and 1984 revealed elevated concentrations of polyaromatic hydrocarbons  (PAHs)
in the disposal pits.  The State lead remedial  investigation/feasibility  study
(RI/FS) for  the  site was  completed  in  November 1986,  and  the  ROD  was signed
March 27,  1987.

     Four potentially  responsible  parties (PRPs)  have been  identified for the
site, including three landowners and one transporter of the waste.  None of the
PRPs has complied with an administrative order to  install a fence  around the
main disposal area, nor have they indicated any responsibility  or willingness
to fund any portion of  the cleanup.

Description of Site Work

     The State initiated an RI/FS for the site in  March 1985, and RI activities
were conducted in February and June  of 1986.  The sampling  efforts identified
several areas  of soil that were moderately  to  highly contaminated  with  PAHs,
particularly  benzene   and  naphthalene.     Because  Frontier  Park  Road  has
significant quantities of contaminated soils and is  the primary  access road for
residents,  the  risk  of  exposure through  inhalation  of dust  particles  and
volatilization of  contaminants  during  wet  periods  is very high.    For  this
reason, the TWC and EPA decided'to address the RI/FS  activities  relating to the
road as  one operable  unit,  and to consider the  storage  pits  and  other site
contamination at a later  date.

Description of Feasibility Study

     The RI/FS developed  the following objectives  for the  Frontier Park Road
operable unit:  (1) prevention  of direct contact with highly contaminated soils;
(2) minimization of direct contact with moderately contaminated  soils; and (3)
improvement of access to the site for heavy equipment to facilitate RI sampling
and monitoring and future  remedial actions.
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     During the detailed analysis of alternatives  the  following  eight  remedies
were considered:

          (1)  On-site  storage with relocation;

          (2)  On-site  storage with detours;

          (3)  Off-site disposal with relocation;

          (4)  Off-site disposal with detours;

          (5)  Fence  around  perimeter  of  contaminated  area,
               pavement   cover  on  contaminated  soils,   and
               temporary alternative access;

          (6)  Removal of contaminated soils to attain background
               levels of contamination, and  off-site disposal;

          (7)  Construction of surface barrier; and

          (8)  No action.

     The  alternatives  were evaluated  and rated with  respect to performance,
reliability,  engineering    implementability/constructability,  environmental
impacts,  costs,  the requirements of CERCLA  for  using permanent solutions  and
treatment  technologies,  and  ability  to  meet   applicable  or  relevant   and
appropriate requirements  (ARARs).   The RI/FS  identified the following ARARs:
Resource  Conservation  and  Recovery  Act  (RCRA)  Part  264 General  Facilities,
Ground-water Protection,  and Closure  regulations;  and the Clean Air Act (CAA)
National  Ambient Air Quality  Standards  (NAAQS).   The  Federal  Water Quality
Criteria  (WQC)  are  also  listed in  the  ROD  as  ARARs,  but the ROD  does  not
indicate whether any of the proposed remedies will attain these  criteria.

     Public meetings concerning the site were held in November 1985  and  November
1986.  Because of the public's  interest in the site, a State disposal permit  was
revoked in 1974;  citizens  currently  are  concerned that the  site might be used
for future disposal  of  waste  from  other Superfund sites.  Residents were also
concerned about drainage and health problems associated with the  contamination.

Description of Selected Remedy

     The  recommended   alternative  was   on-site   storage   with  relocation
(Alternative  1) ,  and involved excavation and removal  of highly contaminated
soil,  backfilling  with  clean  soil,  temporary  on-site   storage of  soil,
construction of a road over excavated areas and existing roadway, and temporary
relocation of residents during excavation.

     EPA indicated that the chosen remedy is expected to comply with ARARs,  and
is the lowest-cost remedy that mitigates  short- and  long-term threats  to human
health  and  the environment.   Operation  and maintenance of the on-site RCRA
storage area  will consist of maintaining and  operating a leachate collection
system.  EPA will conduct operation and maintenance  of  the leachate collection


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system for the first year  after which time the State  of Texas will assume full
responsibility.   EPA  will  be responsible  for the operation  and maintenance of
the road and temporary  storage  facility until a final remedy is selected.
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                     CONSERVATION CHEMICAL COMPANY SITE
                             KANSAS CITY, MISSOURI


HRS Score: 29.99                                                  NPL Rank: Group 15

Background

     The Conservation  Chemical  Company (CCC) site  is  located within the  city
limits of Kansas City,  Missouri.  The  6-acre site  is situated on  the  floodplain
of the Missouri River and is underlain by  the Missouri  River  alluvium,  a source
of drinking water both for private residents and public water-supply  companies.
From 1960 to 1980, the site was  used as a  chemical treatment  and  disposal area,
and it received liquids,  solids, and sludges.  Operating records  indicate  that
the  CCC  facility  received  as  much  as  330,000  tons  of  material,  primarily
composed of  organics,  solvents,  acids, metal hydroxides,  cyanide, pesticides,
waste oils,  and halogenated compounds.  Most of the materials reportedly  were
disposed of  on site, with or without treatment, in  large basins  or lagoons.

     In 1975, the Missouri Department  of Natural  Resources (MDNR)  investigated
the site and requested that  CCC cease  the disposal  of  wastes  and take  remedial
action to  clean up  the  site.   In  1977,  the Missouri Clean Water  Commission
ordered the  site closed and  covered.   CCC submitted a  plan for closure  in  1979
that called  for   adding  adsorbents and cementing materials  to the upper  five
feet of waste of each basin as a temporary measure to prevent migration.  Tests
conducted on samples in  1985, however, indicated that the desired cement-like
properties had not formed.

     EPA and MDNR located potentially  responsible  parties  (PRPs)  for  the wastes
disposed of at the CCC site.   The  PRPs,  including  IBM,  AT&T Technologies, Inc.,
Armco, Inc.,  and FMC  Corporation, undertook a Remedial Investigation (RI) in the
early 1980s to determine  the extent of ground-water  contamination.  EPA  entered
into a joint agency  agreement with the U.S. Army Corps  of Engineers  (COE)  to
complete a Focused Feasibility Study (FFS) in 1985.   An Addendum  to the  FFS was
completed in 1987 after EPA determined that  the initial alternative recommended
for the site would be difficult to implement.  The  ROD for the site  was  signed
September 30, 1987.

Description of Site Work

  The RI conducted by the PRPs identified  21 substances in  ground water  beneath
the site in  concentrations that substantially exceeded the applicable criteria
or standards for  water quality.   The  primary constituents identified were six
metals, cyanide,  four phenolic compounds,  and 10  volatile  organic compounds
(VOCs) .   Dioxin also was detected in concentrations  as high as 29  parts  per
billion (ppb).  (A level  of 1 ppb  is recommended as  a guideline for permissible
concentrations where direct contact is likely.)  The RI also  indicated  that the
greatest exposure  pathway  was associated  with wastes  buried at  the site  that
were  in  contact  with  the  aquifer;   the   second   pathway   of   exposure   was
contaminated surface soils.
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Description of Feasibility Study

     The original joint EPA/COE FFS assembled available  technologies  into  nine
combinations of  alternative  remedial  actions,  and also proposed a  "no  action"
alternative.  Of these,  the government chose circumference containment of wastes
and  on-site ground-water withdrawal  and  treatment  as  the  preferred  option.
Additional geotechnical analysis,  however,  revealed that implementation of  this
remedy would be more difficult than originally believed.  Because of  this,  and
because  the SARA  amendments to  CERCLA in  1986   added  new criteria for  the
evaluation  of  remedies,  an  Addendum  to  the  FFS was  prepared  to  consider
additional remedial action alternatives.

     The Addendum  to  the  FFS conducted  by the  COE developed alternatives  for
remedial actions that met the statutory preferences of CERCLA,  including use of
permanent solutions and alternative treatment technologies to the maximum extent
practicable, compliance with all  Federal and State applicable or relevant  and
appropriate  requirements   (ARARs),  and  protection  of  human  health  and  the
environment.   In addition  to the  preferred alternative under the initial  FFS,
the Addendum proposed  two  additional  remedies  for full  evaluation  against  the
CERCLA criteria:

           (1)  On-site  containment  of  contaminants  by  ground-water
               pumping and on-site treatment; and

           (2)  Excavation of hazardous  materials,  followed by  soil
               treatment.

     ARARs  identified  during  the  Addendum  to  the   FFS  for  ground-water
remediation  at  this  site  included  Safe  Drinking Water  Act  (SDWA)  Maximum
Contaminant Levels  (MCLs)  and Maximum  Contaminant Level Goals (MCLGs); Clean
Water Act (CWA) Water Quality Criteria,  health  advisories,  Potency Factors,  and
verified Reference  Doses;  and Resource Conservation and  Recovery  Act (RCRA)
ground-water protection standards.  ARARs  for discharges to  the Missouri River
included the CWA and the Missouri Clean  Water Law.  ARARs for soil  remediation
included RCRA  closure requirements.

     Public notices were issued requesting comments on the draft RI,  FFS,  and
the addendum to  the FS, a court hearing  with defendants, the completion of the
Addendum to the FFS,  and  the selection of the  final  remedy.   However,  few
comments were  received  from  the public.

Description of Selected Remedy

     The alternative selected was containment of contaminants through an on-site
ground-water pump and treatment system.   Specifically,  this  remedy incorporates
surface cleanup, a protective surface cap, a withdrawal  well system,  a ground-
water treatment system, and an off-site ground-water quality monitoring system.
This remedy was determined  to be protective of human health and  the environment,
cost-effective,  and in compliance with the statutory  mandate  to   achieve  all
ARARs.  The State of Missouri concurred  with the final  remedy selected.
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                       MINKER/STOUT/ROMAINE CREEK SITE
                         ROMAINE CREEK OPERABLE UNIT
                          JEFFERSON COUNTY, MISSOURI


HRS Score:  36.78                                                      NPL Rank: 474

Background

     The Minker/Stout/Romaine Creek hazardous  waste site is located in Jefferson
County, Missouri, approximately 20 miles southwest of St. Louis.  Romaine Creek,
located in a  rural residential  area,  starts  at the Minker area  and flows  4.6
miles to its confluence with Saline Creek,  which empties into  the Meramec River
0.2 miles  down-stream.   The  water  from  Romaine Creek  is  used neither  for
domestic water supply nor for municipal or  industrial purposes.

     Romaine Creek is  contaminated with dioxin from  the  erosion of  120 cubic
yards of soil deposited at  the Minker  property, which is being  addressed as  a
separate operable unit.   The contaminants  in Romaine  Creek originated  from  a
chemical plant in southwest Missouri, that  produced hexachlorophene  and dioxin
in the late 1960s and early 1970s. In March 1973, dioxin-contaminated soil was
deposited at several locations  that  now constitute the individual' portions of
the Minker/Stout/Romaine Creek site.   Since 1973,  a  significant quantity of the
Minker fill  has  eroded  into  Romaine Creek.   The Stout  area,  which  is  being
addressed as another operable unit,  is  nearby, but not  adjacent  to,  the Minker
area.    Because  of the  similarities  of the three areas,  the remedial  action
selection process for all three operable units was conducted  simultaneously.

     Cleanup actions taken to date include  the excavation of  soils exceeding  1
ppb dioxin at the Minker area in 1986,  and the posting of warning signs along
the contaminated  portion of Romaine Creek.  The Romaine  Creek  Operable  Unit
Feasibility Study (FS) was completed in July  1987, and  the ROD  for the interim
remedy was signed September 28, 1987.

Description of Site Work

     EPA initially sampled  and analyzed Romaine Creek sediments  for  dioxin in
1982.   On the basis of  150 samples, EPA determined the  dioxin contamination at
a level of 1 ppb  extended approximately 6,000 feet downstream from  the  Minker
area.   In  1985, biota  and additional  sediment  samples were collected,  revealing
dioxin concentrations  as high as  36.3 ppb 0.5 mile downstream from the site,  and
concentrations of 0.3  ppb  4.5  miles   downstream  from the  site.   The  biota
sampling detected dioxin in all  aquatic species  sampled  (fish,  crayfish,  and
amphipods) at levels greater than  50 parts  per trillion (ppt).

Description of Feasibility Study

     The objectives of  the  EPA lead FS included:   (1)  preventing or  reducing
long-term human contact with soils containing dioxin at concentrations exceeding
1 ppb, the level  that is determined to be protective of human health and the
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environment; and (2) minimizing the  potential  for off-site  migration of dioxin.
The following operable unit remedial action alternatives were developed:

          (1)  No Action;

          (2)  Limited   action   --   implementation   of   site-use
               restrictions, and annual monitoring  of Romaine Creek
               and nearby wells;

          (3)  Stabilization of sediments  to achieve maximum of 1 ppb
               dioxin contamination using  vegetation and manufactured
               erosion-control mats;

          (4)  Excavation to 1 ppb and  temporary on-site storage; and

          (5)  Complete excavation and storage of all sediments within
               Romaine Creek.

     Because the operable unit  alternatives evaluated for this  FS represent only
part of the complete remedy for Romaine Creek, it is not necessary for them to
comply with applicable or relevant and  appropriate requirements (ARARs) for the
entire site. All operable unit alternatives evaluated are  consistent with final
remedial actions; these final remedial actions potentially could meet all ARARs.
ARARs identified for this operable unit include land disposal restrictions for
dioxin-contaminated wastes  and Resource  Conservation and  Recovery Act (RCRA)
storage requirements.

     As with  the Stout and Minker  operable units,  affected  residents  are in
general agreement that the contaminated soil should be  excavated and transported
off  site  for  treatment  and  disposal.    Given the  absence  of  an  off-site
management option,  the public is expected  to accept  interim storage as the only
alternative available at this time.   Some local objection  is expected near the
location where the  required  on-site  storage structures will be  built.  The state
has indicated its support for excavation and interim storage of sediments with
contamination exceeding 1 ppb dioxin at Romaine Creek.

Description of Selected Remedy

     The remedy  selected for this  operable unit involves  excavation of creek
sediments with greater than  1 ppb dioxin contamination by using vacuum equipment
or  other  appropriate  means.    Innovative  excavation  techniques,  particle
separation technologies, and other procedures  capable  of reducing the amount of
material removed from  the creek (and reducing environmental disturbance) will
be examined during the  design phase.  Excavated sediments will  be  stored in four
fully-enclosed temporary storage structures constructed on-site  until a final
treatment, storage, or disposal option can be selected.  If a final management
alternative becomes  available, it  is  possible  that contaminated  soil  can be
taken directly to the location where final management  is available.  The Agency
has proposed off-site thermal treatment of contaminated soils as a final remedy.
Such  a  remedy  would   satisfy  CERCLA  statutory preferences for permanent,
treatment-based remedies.
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     This remedy  mitigates the  potential for human  and environmental  contact
with contaminated sediments and  reduces the possibility  of  continued erosion of
these  sediments.     In  addition,  it   is   more  protective,  reliable,   and
implementable  than other  alternatives,  and  it  results  in less environmental
disruption than complete  excavation of all sediments.
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                       MINKER/STOUT/ROMAINE CREEK SITE
                             STOUT OPERABLE UNIT
                          JEFFERSON COUNTY, MISSOURI


HRS Score:  36.78                                                     NPL Rank: 474

Background

     The Minker/Stout/Romaine Creek hazardous waste site is located in Jefferson
County, Missouri,  approximately 20 miles  southwest  of St. Louis.   The Stout
site, comprises five properties  (the Vogt property, the Sutton property,  and the
former Hutchinson, Cisco,  and Baczynski properties)  and is located near  the top
of a steeply  sloping  hillside  in an unincorporated,  low-density  area  near
Imperial,  Missouri.

     Dioxin  contamination exists  in  surficial  soils on  most of  the   Sutton
property and on  adjacent  portions  of  the  Vogt  and Hutchinson properties.   The
contaminants originated  from a chemical  plant  in southwest  Missouri, which
produced hexachlorophene  and dioxin in the late 1960s and early 1970s. In March
1973,  dioxin-contaminated soil  was  deposited at  several locations that  now
constitute  the individual  portions  of the  Minker/Stout/Romaine  Creek site.
Approximately  700  cubic yards  of this soil were  deposited at the Stout area.
The Minker/Stout/Romaine  Creek  site also  includes  the Minker area,  a tract of
land  nearby,   but not adjacent to,  the  Stout  area,  and  Romaine  Creek,  a
contaminated creek running from  the Minker area.  Each of  these areas is being
addressed as a  separate operable unit.  Because of the similarities of the three
areas, however,  the remedial action selection process  for all three operable
units was  conducted simultaneously.

     Remedial actions  performed by  EPA to  date  include the permanent  relocation
of three residences following discovery of dioxin contamination in  1982.   The
Stout Operable Unit Feasibility  Study  (FS) was completed  in July  1987,  and the
ROD for the interim remedy selected was signed September  28,  1987.

Description of Site  Work

     Several  investigations of soil  contamination  at  the  Stout  area  were
conducted during 1982, 1983, and  1986.   These  investigations indicated  that
dioxin  levels  in  the soil  (up to  241  ppb)  require  remediation  to   assure
protection  of  human health and  the environment.   According to 1983  sampling,
contamination was limited to the Stout area and approximately  800  feet along an
unnamed intermittent stream.  A maximum dioxin  concentration of 11 ppb has  been
detected in this  portion  of the stream.   The 1986 sampling indicated that the
areal extent of contamination exceeding 1 ppb is approximately  1.1 acres.

Description of Feasibility Study

     The objectives of the FS  conducted  by EPA included:   (1) prevention or
reduction   of  long-term   human contact   with  soils  containing   dioxin  at
concentrations exceeding  1 ppb,  the level at or below that which  is  determined
to be protective of public health  and  the environment;  and (2)  minimization of
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the potential  for  off-site  migration of dioxins.   The following five  remedial
action alternatives were developed  for  the  site:

          (1)  No action;

          (2)  Limited   action   --   implementation   of   site-use
               restrictions, seeding of sparsely vegetated areas, and
               surface-water controls and annual monitoring;

          (3)  Stabilization  of soils  to  achieve maximum  of 1 ppb
               dioxin contamination;

          (4)  Excavation   to   achieve   maximum  of  1  ppb  dioxin
               concentration and temporary  on-site storage;  and

          (5)  Complete excavation  and  storage.

     Because the operable unit alternatives  evaluated for this FS  represent only
part of the complete remedy for the Stout area,  it is  not necessary for them  to
comply with applicable or relevant and appropriate requirements  (ARARs) for the
entire site.  All operable unit alternatives evaluated are consistent with final
remedial actions; these final  remedial actions potentially could meet all ARARs.
ARARs identified for this operable  unit include land disposal restrictions for
dioxin-contaminated wastes, and Resource Conservation and Recovery Act  (RCRA)
storage regulations.

     Affected  residents  are in  general agreement that  the contaminated  soil
should be excavated and transported off site for treatment and disposal.   Given
the absence of an off-site management option, the public  is  expected to  accept
interim storage  as the only  alternative available at this  time.   Some  local
objection  is  expected near  the location where the  required on-site  storage
structures will be built.  The State of Missouri has indicated its  support for
excavation  and interim  storage  of  soils with  contamination exceeding 1 ppb
dioxin at the Stout area.

Description of Selected Remedy

     The remedy  selected for  this  operable unit  involves excavation  of  soils
with contamination exceeding  1  ppb dioxin  to  a maximum  depth of 4  feet  of
bedrock.   Excavated areas  will be backfilled to  original  grade  with  clean
material and revegetated.  Excavated soil will be  stored in four fully-enclosed
temporary  storage  structures  constructed on site,  until  a final treatment,
storage, or disposal option can be selected.  If a  final management  alternative
becomes available,  it is possible that  contaminated soil can be taken  directly
to the location where  final management  is available.   Although a final  remedy
has not been  selected for  the  entire  site,  the Agency  has proposed  off-site
thermal treatment  of  contaminated soils.   Such a  remedy would satisfy  CERCLA
statutory preferences for permanent, treatment-based remedies.

     The selected  remedy is cost-effective and protects  human  health and the
environment by  reducing the  potential  for continued  erosion of contaminated
soils.    In comparison  with the selected  remedy,  complete  excavation of the
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entire  fill area  cannot be  justified  at  the  additional  cost  because both
alternatives reduced  surface  dioxin concentrations to below  1  ppb,  the level
that assures protection of public health and the environment.  Stabilization of
contaminated  soils was  not  proposed  due  to  the  uncertainty  of successful
implementation and high operation  and  maintenance  requirements.
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                         CLEAR CREEK/CENTRAL CITY SITE
                                OPERABLE UNIT I
                  CLEAR CREEK AND GILPIN COUNTIES, COLORADO


HRS Score: 5139                                                     NPL Rank: 157

Background

     The Clear  Creek/Central  City  site is  located in the northeastern portion
of the Colorado Mineral  Belt, approximately  30 miles west of Denver,  Colorado,
near  the cities of  Idaho  Springs,  Black  Hawk,  and Central City.   Acid  mine
drainage and milling and mining waste  discharges  from five abandoned  mines and
tunnels at the site caused surface-water contamination consisting  of  dissolved
and suspended metals, including aluminum,  cadmium, and lead.

     The Clear  Creek/Central  City mining  site is one  of the more  extensively
mined areas in  Colorado.   Mining  and construction of the tunnels began  in the
early 1900s,  and the entire area includes  over 800 abandoned mine workings and
tunnels.  The Clear  Creek/Central  City site  was  added to the NPL in  1983,  and
EPA began  a Remedial  Investigation  (RI)  for the  entire  site  in June  1985.
During the RI,  EPA determined that an interim remedy operable unit was  needed
to address  treatment  of mine  drainage.   A feasibility  study (FS)  for  the
Operable Unit I  remedy was  completed in June  1987  and  the ROD  was  signed
September 30,  1987.   Separate  FSs will be prepared for Operable  Units II through
III to  address  additional site degradation.  The determination of the  final
remedy is contingent upon the completion of  the operable units.

     A potentially responsible party (PRP)  search did not identify  any PRPs for
the mine tunnel  discharges,  which are the focus  of  Operable Unit  I.   The  PRP
search,  however,  revealed information concerning ownership of  mine  tailings
which have been identified as a source of metals  contamination  of surface water
resulting from seepage of ground water  through the tailing piles.  Operable Unit
II will address contamination from this source.

Description of Site Work

     The RI for  the  entire site was  completed in June 1987 and  indicated  that
concentrations of metals in the mine tunnel  discharges exceed Federal  drinking
water standards.  Ambient water quality criteria,  which are designed to protect
aquatic  life, have also been exceeded, in certain  instances by more  than  two
levels  of  magnitude.    A  public  health   evaluation (PHE)  identified  eleven
contaminants  of  concern:     aluminum, arsenic,  cadmium,   chromium,  copper,
fluoride, lead,  manganese,  nickel,  silver,  and zinc.   Risks to human and aquatic
life are associated  with exposure to  surface water  from ingestion and  direct
contact.  The  PHE showed that  there  is no  immediate  danger from mine  tunnel
discharge at  present  flow rates, although mine tunnel discharges have had  severe
adverse impacts on water quality and the aquatic habitat.
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Description of Feasibility Study

     Alternatives identified in the FS were  initially  screened  on the  basis  of
cost, effectiveness, and  implementability.   These remaining alternatives  were
subject to a detailed analysis:

           (1)  No action;

           (2)  Passive  treatment -- creation of an artificial wetland
               to  emulate  or enhance natural  metal  ion removal  and
               acidity  reduction processes;

           (3)  Active treatment -- alkaline precipitation (using  lime,
               sodium   hydroxide,  or  sulfide)   or  electrochemical
               precipitation; and

           (4)  Combination of active and passive  treatment.

     Contaminant-specific  ARARs  for the site are Maximum Contaminant  Levels
(MCLs) under the  Safe  Drinking Water  Act  (SDWA)  and Ambient Water Quality
Criteria  (AWQC)  established under  the  Clean Water Act  (CWA).   State ARARs
include State  water quality and anti-degradation standards.   Location- and
action-specific  ARARs   include  historic preservation  regulations,  executive
orders on  floodplains and wetlands, the National Pollution Discharge Elimination
System (NPDES),  and  Subtitle D of the Resource  Conservation and  Recovery Act
(RCRA).

     Community relations at the site  included public  meetings  after the release
of the Operable  Unit I  FS,  the  establishment of  information repositories, and
establishment of the administrative record.

Description of Selected Remedy

     The selected  interim  remedy  for  Operable Unit I consists  of construction
of passive treatment systems to treat  mine tunnel  discharges prior to discharge
to surface waters  (Alternative 2) .  If  upstream  water quality concentrations
cannot be  achieved by passive treatment,  then one of the following two treatment
systems will be  constructed:

           •    Combination system of passive and active treatment;  or

           •    Two active treatment systems.

     The  selected interim  remedy  is  cost-effective  and  is   expected  to  be
protective of human health  and the environment.  Target treatment levels for the
interim remedy are upstream  water  quality concentrations.  The interim  remedy
requires the exercise  of the CERCLA section 121  "interim remedy" waiver  from
contaminant-specific ARARs.  EPA intends that  the final remedy  will, at  least,
attain water quality criteria established under the CWA.   The  interim remedy  is
expected to  be consistent with  the  final site remedy.   In addition, passive
treatment  is an  innovative technology,   and  the installation  of  either  of the
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treatment systems meets the  CERCLA statutory preference  for permanent solutions
that reduce the mobility, toxicity, or volume of metals in the  discharge.
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                              DENVER RADIUM SITE
                  OPERABLE UNIT I -- 12th AND QUIVAS PROPERTIES
                               DENVER, COLORADO

HRS Score:  44.11                                                     NPL Rank:  284

Background

     Operable Unit I of the  Denver Radium site consists of 4 of the more than
31 radioactive  properties that  EPA  has  identified  in  the Denver  area.   The
radioactive contamination at the Denver Radium site properties originated from
a number of radium, vanadium, and uranium processing operations conducted during
the 1910s  and  1920s.   Because of the enormity of  the Denver Radium site, EPA
divided the site into 11 operable units.  Operable Unit I is located  at the 12th
and Quivas  Streets properties  in the City of Denver,  where releases of radium
and  its  associated  decay products  are  the  hazardous  substances  of primary
concern.   The properties  cover  approximately  8  acres  in an area  zoned for
industrial  use  and currently  are  in use  for business operations  by various
companies.   Until  1924, the  Pittsburgh Radium  Company,  a  division  of the
National  Vanadium Products  Company,  refined  radium-bearing  ore at  the  site
location,   and  the current contamination is believed  to be the  result of this
Company's operations.

     After EPA identified all 31  contaminated properties,  the  Radiation Control
Division of the Colorado Department of Health (CDH)  notified property owners of
the presence of  radium  and requested that no excavation be undertaken without
consultation with CDH.   In August 1981,  CDH,  in  a cooperative  agreement with
EPA,  initiated  investigation of  many of  the 31 properties.  EPA installed a
vented-plenum wall in the basement  of the  B&C Metal  Products building, which is
included in Operable Unit I,  to reduce radon decay product concentrations.  EPA
did not take further  emergency  response actions at the site because the patterns
of occupancy and the  concentrations of contaminants  during periods of occupancy
reduced the significance of long-term exposure.

     The entire  Denver  Radium  site was  included on the final NPL published in
September  1983.   EPA assumed  Fund  lead  activities in June  1983  because the
Colorado State Legislature failed to appropriate the  cost-share required.   EPA
initiated the Remedial  Investigation (RI) in December 1983, and the RI for all
operable  units  was  completed  in April  1986.    The draft  Operable Unit  I
feasibility  study (FS)  was  released in August 1987,  and  the ROD  was signed
September 29, 1987.

     A potentially responsible party  (PRP) search has  not  traced the Pittsburgh
Radium Company to any firm that is  currently operating.  EPA is proceeding with
a Fund-financed  remedial design  and  remedial action.   If PRPs are  identified,
EPA will attempt  to recover response costs from the PRPs.

Description of Site Work

     Radium and  its  associated decay products are the primary contaminants of
concern.  Long-term exposure  to these substances has been  shown conclusively to
increase the risk of  contracting  lung cancer.  EPA used a gamma radiation survey
to outline the extent of possible radium contamination and verified the presence


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of radium  in the soil and underneath  the  buildings on site by  radio-chemical
analysis of  subsurface soil samples.   Radium concentrations, gamma  radiation
levels, and  radon decay product concentrations  found  in three  buildings  on the
site  were  of  concern because  they exceeded  the EPA  Standards for  Remedial
Actions at Inactive Uranium Processing  Sites.

Description of Feasibility Study

     EPA evaluated remedial  alternatives against the CERCLA requirements  that
a remedy be  protective of  human  health and  the  environment; cost effective;
attain Federal  and  State applicable or relevant and appropriate requirements
(ARARs);  and use permanent solutions and alternative  treatment technologies to
the maximum  extent practicable, with preference  for  remedies  that permanently
and  significantly  reduce  the toxicity,  mobility,  or  volume  of   hazardous
substances.  The alternatives  developed in the  FS were:

           (1)  No action;

           (2)  Deferred removal and off-site  permanent  disposal;

           (3)  On-site reprocessing/treatment and off-site  permanent
               disposal;

           (4)  In situ vitrification;

           (5)  On-site permanent disposal;

           (6)  Off-site permanent disposal;

           (7)  On-site temporary land storage and off-site  permanent
               disposal;

           (8)  On-site  temporary   building   storage   and  off-site
               permanent disposal;

           (9)  On-site temporary  containment  (capping) and off-site
               permanent disposal;  and

           (10) Temporary storage at the Card Corporation property and
               off-site permanent disposal.

     Federal ARARs  identified for  the  site  included:   the EPA Standards  for
Remedial Action  at  Inactive Uranium Processing Sites,  the Nuclear Regulatory
Commission Standards for Protection Against Radiation,  the  National Council on
Radiation  Protection  and Measurements, and  the International  Commission  on
Radiological Protection recommendations  for gamma radiation doses.

     In July 1987 ,  EPA met with the  owners  and tenants of the properties  on the
site.   Topics discussed included concerns  about adverse publicity to  the firms
on site and  details of the  remedial action phase.  In August  1987, EPA  held a
public meeting where  concerns raised included  the effect of  the remedial  action
on business  operations on site and the  liability of  owners and tenants.   The
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public  generally  supported  the  complete  excavation  and  permanent  off-site
disposal of all materials.

Description of Selected Remedy

     The  initial  preferred  alternative for  the  site was  permanent  off-site
disposal.  Until the State of Colorado  agrees to a permanent  disposal  site for
material  removed  from  the  properties,  however,   this alternative  cannot  be
implemented.  Consequently, the  remedial design for Operable Unit 3 includes on-
site  temporary containment  and off-site  permanent  disposal.   The  temporary
response action  consists of capping  the  contamination at  the properties  and
excavating materials from under three buildings  and temporarily storing them on
site.  The  final  and permanent  source control response action will  occur when
a disposal facility becomes available.  Included in the remedy is  review of the
site pursuant to CERCLA section  121(c) if any hazardous materials remain on site
for more than  5 years.

     The selected alternative is cost-effective,  is expected to meet ARARs, and
provides adequate protection of  public health and the environment.   The selected
remedy, however,  does  not  satisfy the preference  for treatment as  a principal
element.   Because  of   the  radioactive nature  of  radium,  no  technology  was
identified  that  would  result  in a permanent  or  significant  decrease  in  the
toxicity, mobility,  or volume of  the  radium on site.
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                              DENVER RADIUM SITE
                OPERABLE UNIT II -- 11TH AND UMATILLA PROPERTIES
                               DENVER, COLORADO

HRS Score: 44.11                                                     NPL Rank: 284

Background

     Operable Unit II of the Denver Radium site consists of 11 of the more  than
31  radioactive  properties that EPA has  identified in the Denver  metropolitan
area.   The  radioactive  contamination at  the  Denver  Radium site  properties
originated from a number of radium,  vanadium,  and uranium processing operations
conducted during  the 1910s and 1920s.   Because  of the enormity of  the  Denver
Radium Site, EPA divided the site into 11 operable units.  The 11 properties  in
Operable Unit II cover approximately 24 acres and are currently used for various
business  operations.   The  contaminants  of  concern,   radium and  its  decay
products, can be traced  to the Radium  Company of  Colorado, which  processed
radium-bearing ore on the  Operable Unit  II  site  until  1921.

     After EPA identified the 31 radioactive properties,  the  Radiation Control
Division of the Colorado Department of Health (CDH) contacted the owners  of the
properties  and requested that  no  excavation  be  done  on   the  site without
notification  of the  Division.   In 1981,  CDH,  in a cooperative  agreement  with
EPA, assumed lead activities at the Denver Radium site.   Among other activities
on  the  Operable  Unit  II, CDH  and EPA  oversaw the  installation of  subfloor
venting measures  and a vapor barrier  at  the  DuWald Steel property  to prevent
radon from entering  the building.   The entire Denver Radium  site  was  included
on the NPL in September 1983.  EPA assumed Fund lead activities in 1983 when the
Colorado  State  Legislature failed to  appropriate the  State  cost share.  The
Remedial Investigation  (RI)  for all  the  operable units was completed  in April
1986.  The feasibility study (FS) for  Operable Unit II  was completed in  August
1987, and the ROD was signed September 29,  1987.

     A potentially responsible party (PRP) search has failed to trace the  Radium
Company of Colorado to a present-day company.   If PRPs  are identified,  EPA  will
contact them and  initiate  negotiations for  the implementation of the remedy  or
take action to recover EPA's response  costs.

Description of Site Work

     Sampling  conducted   during   the   EPA  lead  RI  indicated   that   radium
concentration in the soils and the  radon  decay product  concentrations and gamma
radiation levels  in  certain  buildings  exceeded the EPA Standards  for  Remedial
Actions at Inactive Uranium Processing Sites.   Long-term exposure to radium and
its  decay products  has  been  shown  conclusively to  increase  the  risk  of
contracting lung cancer.   Although radon  levels in two buildings on the Operable
Unit II site exceed the EPA standards,  EPA took no  emergency action because one
building is presently  unoccupied,  and the  patterns  of occupancy in the other
building reduce the chances of significant long-term exposure.   The RI indicated
that  contaminants at  the site  pose  a  health  risk through three potential
exposure pathways:  inhalation, direct gamma radiation  exposure,  and ingestion
of  radium-contaminated  materials.   The  health risk at  the  site results  from
possible long-term exposure,  and this exposure  would increase  if any of the


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contaminated  material  was  to become  more  accessible,  if the  property  was
redeveloped, or  if the  buildings  on  site  became more airtight or more heavily
used.

Description of Feasibility Study

     The FS for the  11 properties  in  Operable Unit II  evaluated alternatives in
accordance with  the  CERCLA requirements that a  remedy be protective of  human
health and the environment,  cost-effective,  attain Federal and  State  applicable
or relevant and  appropriate  requirements  (ARARs), and use permanent  solutions
and alternative treatment technologies to the maximum extent practicable.   After
an initial  screening,  the  following remedial alternatives  were retained  for
detailed analysis:

          (1)  No action;

          (2)  Deferred removal and  off-site permanent  disposal;

          (3)  On-site  temporary land storage and off-site permanent
               disposal;

          (4)  On-site   temporary  building  storage  and   off-site
               permanent disposal; and

          (5)  Temporary  building storage  at  the  Card  Corporation
               property and off-site permanent disposal.

     Federal  ARARs   identified  for  the site  include  the  EPA  Standards  for
Remedial  Actions  at  Inactive  Uranium  Processing  Sites,  and  the Nuclear
Regulatory Commission Standards for  Protection Against  Radiation.  The FS also
identified  the  Executive Order  on  Flood  Plain Management  as  a   potential
location-specific ARAR.   Other Federal  ARARs considered  included the National
Council  on  Radiation  Protection   and  Measurements   and   the  International
Commission on Radiological Protection (ICRP) recommendations for maximum  gamma
radiation dose to the entire body.  Additionally,  to comply with  CERCLA section
104(c)  and  EPA's off-site  disposal  policy, the  State of  Colorado  must make
available a disposal facility.

     A  public  meeting was held in August 1987.  Major concerns of  those  who
attended  the  meeting were  the  effect  of  the  remedial action  on business
operations at  the site,  the  liability of  the owners at the  site, and the cost
of the  remedial  action.    In general,  the  community  had reservations  about
temporary actions that leave contaminants  on site and,  consequently,  the public
supported the  excavation and permanent off-site  disposal of  the contaminated
material.
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Description of Selected Remedy

     The selected  remedy  for Operable Unit II of the Denver Radium site  is  on-
site temporary land storage  and off-site permanent  disposal.   When the  State of
Colorado  agrees  to  a  disposal  facility,  EPA will  implement  its  preferred
alternative, off-site permanent  disposal.

     The alternative  is protective of the  public health, is expected to  attain
ARARs, and is cost effective. Because of  the radioactive nature  of radium,  no
technology was  identified that  would result  in  a permanent and significant
decrease in  the toxicity,  mobility,  or volume of the hazardous substance.
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                              DENVER RADIUM SITE
               OPERABLE UNIT III -- 1000 WEST LOUISIANA PROPERTIES
                               DENVER, COLORADO

HRS Score:  44.11                                                     NPL Rank:  284

Background

     Operable Unit III  of  the Denver Radium site  consists of five of the more
than 31 radioactive properties that EPA has  identified in the Denver  area.  The
radioactive contamination at  the Denver Radium site properties originated from
a number of radium, vanadium,  and uranium processing operations conducted during
the 1910s  and  the  1920s.   Because of the enormity of the Denver Radium site,
EPA divided the site into 11 operable units.   The  Operable Unit III properties,
known collectively as the 1000 West Louisiana properties, cover 11 acres in an
area  zoned for  industrial  use  and  currently are being  used  for business
operations.

     After EPA identified the 31  contaminated properties,  the Radiation Control
Division of the Colorado Department of  Health (CDH) notified  property owners of
the presence of  radium  and  requested that no excavation be  undertaken without
consultation with  CDH.   In August 1981,  CDH,  in  a cooperative agreement with
EPA,  initiated investigation of many of the 31 properties. Although radon decay
levels  in the  basement of  the  Creative Illumination  Building  at  the  West
Louisiana properties site exceeded EPA standards,   an emergency response action
was not taken because the patterns  of occupancy and the concentrations of radon
decay products present  were  such that  significant long-term exposure risk was
considered unlikely.

     The entire Denver  Radium site was  included on the final NPL published in
September  1983.   EPA assumed Fund lead  activities in June 1983  because the
Colorado State Legislature failed to appropriate  the cost-share required.  EPA
initiated the Remedial Investigation (RI) in December  1983,  and the  RI for all
operable  units was  completed in  April  1986.    The  draft  Operable  Unit  III
feasibility study  (FS)  was  released  for public review in August 1987, and the
ROD was signed September 29,  1987.

     Records  indicated  that  the Chemical  Products Company  (CPC)  operated a
processing facility at the  Operable Unit III site from 1918 to 1921 and disposed
of ore processing wastes containing radium.  Sources indicated that CPC may have
been a division  of  the  Ludlum Steel  Company and may also have been  associated
with the Ore Products Company.  A potentially responsible party (PRP)  search has
not traced  CPC  to  a present-day entity and  has not revealed that the present
owners of the properties have any connection to the activities that  caused the
radioactive contamination.    EPA  is  proceeding with  a Fund-financed remedial
design  and remedial  action  and  will  attempt  to  recover  costs  if PRPs  are
identified.
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Description of Site Work

     Radium  and its decay  products  are the  primary contaminants of  concern.
Long-term  exposure to these substances has been shown  conclusively to  increase
the  risk  of contracting  lung  cancer.   EPA  used a  gamma radiation survey  to
outline the extent of possible radium contamination.   The presence of radium in
the  soil and beneath  the  buildings was verified by  radio-chemical  analysis  of
subsurface soil  samples.   A small number of polynuclear  aromatic hydrocarbons
(PAHs) and volatile  organic compounds were  also  found in on-site soils.   The
radium concentration in the soils on the properties and the radon decay product
concentrations and gamma radiation levels found in one of the buildings  exceeded
EPA standards.   In addition, alpha radioactivity levels in the building exceeded
State of Colorado guidelines.

     The elevated  concentrations  of  radium at the properties present  a health
risk through three potential exposure pathways:  1) inhalation of radon gas,  the
immediate  decay  product of radium;  2)  direct gamma  radiation exposure;  and  3)
ingestion  or inhalation of  radium contaminated materials.

Description of Feasibility Study

     The Operable Unit III FS  identified the  following remedial  alternatives  as
those warranting in-depth evaluation:

           (1)  No action;

           (2)  Deferred removal and off-site  permanent  disposal;

           (3)  On-site  temporary land  storage  and  off-site
               permanent disposal;

           (4)  On-site  temporary  building  storage and off-site
               permanent disposal;

           (5)  On-site temporary  containment  (capping) and  off-
               site permanent disposal; and

           (6)  Temporary building storage at the Card  Corporation
               property and off-site permanent disposal.

     Federal ARARs  identified for the  site  included:    the EPA  Standards for
Remedial Action  at Inactive Uranium Processing  Sites,  the Nuclear  Regulatory
Commission Standards for Protection Against Radiation, the  National  Council  on
Radiation  Protection  and  Measurements,  and  the  International  Commission  on
Radiological Protection recommendations for gamma radiation doses.

     In July 1987,  EPA met with the owners  and tenants  of the properties on the
site.  Neighboring homeowners  expressed concern  over whether their  homes were
contaminated  from the  1000 West Louisiana  properties  and  the cost  of the
remedial action.   In  general,  the public  supports the complete  excavation and
permanent off-site disposal of all contaminated materials.
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Description of Selected Remedy

     EPA1s preferred  remedial action alternative  for the 1000 West  Louisiana
properties is  off-site  permanent disposal.  This alternative, however.,  cannot
be implemented until the State of  Colorado provides  a permanent  disposal site.
Consequently,  the  remedial  action for Operable Unit  III  is  temporary building
storage  at  the  Card  Corporation  property  for material   from  the  Creative
Illumination Building and on-site storage for the remainder of the .material from
the property.  Off-site permanent  disposal (Alternative  6) will  be implemented
once a permanent disposal facility becomes available. The remedy will include
review of the site pursuant to CERCLA section 121(c)  if any hazardous  materials
remain on site for more than  5 years.

     The selected alternative is cost-effective, is expected to meet ARARs,  and
provides adequate protection of public health and the  environment.  The selected
remedy, however, does not satisfy the preference for treatment that a principal
element because  no technology was found which would  result  in a  permanent  and
significant  decrease  in the toxicity,  mobility,  or  volume  of the  radioactive
substance, radium, on-site.
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                              DENVER RADIUM SITE
                 OPERABLE UNIT X -- CARD CORPORATION PROPERTY
                              DENVER,  COLORADO


HRS Score:  44.11                                                      NPL Rank: 284

Background:

     The Denver  Radium  site  includes the  remains  of several radium  processing
facilities  that  operated in  the  1910s and  1920s.   Included  in these  radium
processing operations are facilities developed by the U.S.  Bureau of Mines and
a private corporation,  the National Radium Institute (NRI).  In 1979,  references
in a 1916 NRI report led EPA to  discover 31  sites  contaminated  with radioactive
materials  in  the  Denver  area.   One of  these  sites  is  the  17-acre Card
Corporation property, which was used as a radium processing facility from 1920
to 1924 by the Pittsburgh Radium Company.   The industrial-zoned  site was owned
by the Card Corporation when radiological  contamination was discovered.   Mentor
Corporation  acquired the property  in 1977 without  having knowledge  of the
contamination on the site.

     The Denver Radium site was  placed on  the final  NPL in September  1983.  Due
to its enormity,  the Denver Radium site has been divided into 11 operable  units,
of which  the  Card Corporation  property  is  Operable  Unit X.   The Colorado
Department of Health (CDH) assumed the  lead  in assessing the various  properties
in August 1981.  However, the current  owner of the Card  Corporation property,
the Mentor Corporation, denied the State access to  the  site.   Subsequently, an
EPA  lead  Remedial  Investigation  (RI)   of  the entire  Denver  Radium site was
initiated  in December  1983.    Draft  feasibility studies  (FS)  for the Card
Corporation property Operable Unit were released  in 1986  and 1987, and the ROD
was signed June  30, 1987.

     A search for potentially responsible parties (PRPs)  for the entire  Denver
Radium site has been initiated,  but no  PRPs  have been  identified  as responsible
for the contamination on  the  Card  Corporation property.  The  attempt to trace
the Pittsburgh Radium Company to  a present-day company has been unsuccessful.
EPA is negotiating  a covenant with Mentor not to sue for potential liability
resulting from a release of hazardous substances at the site.  In  return,  Mentor
would provide  EPA access to  its  property for storage of  radium-contaminated
materials from other units at the Denver Radium site.

Description of Site Work

     The EPA lead RI, completed in April  1986,  indicated that the contaminant
of concern  at  the Card Corporation  property is  radium.   Results  of a  gamma-
radiation survey indicated that radium was  present  in the  soil,  in  buildings,
and underneath  the  buildings.  The  radium  concentration potentially  poses a
health hazard  through three  principal exposure  pathways:   (1)  inhalation of
radon gas, the immediate  decay  product of radium, and radon's own short-lived
decay products;  (2)  direct gamma  radiation  exposure from the  decay  of radium;
and (3) ingestion or inhalation of radium-contaminated materials.  Because the
radium at this site is in a  form that is relatively  insoluble,  and migration of
contaminants into the  ground  water or pond  water was  not found, ingestion of


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radium from contaminated surface water or ground water was not a concern at the
Card Corporation property.

Description of Feasibility Study

     A first draft of the FS was released  for  public review in October  1986.
Because public concern was so great,  the comment period on the FS was  extended.
The primary concern of the public was that the temporary storage facility would
become permanent if the State failed to assure  the availability of  a  permanent
disposal site.   Subsequently, the City Council passed a resolution opposing the
storage of any radioactive  waste anywhere  in  the  Denver metropolitan  area.
Other major  concerns  raised at the public  meeting  in November  1986  included:
the impacts of cleanup  and storage  on area property values;  the justification
for  temporary  storage;  health risks  from  the cleanup;  and  the  risks  from
transporting material to the site.

     A second  draft  FS, reflecting comments received on the first draft,  was
released  for public  comment  in April  1987.     It  also  incorporated  CERCLA
requirements  for  considering   permanent  solutions  and  use  of  treatment
technologies to the maximum extent practicable and attainment of ARARs.  Of nine
alternatives originally considered, five remained after screening:

           (1)  No  action;

           (2)  Deferred removal with off-site permanent disposal;

           (3)  On-site permanent  disposal;

           (4)  On-site  temporary  land  storage  with  off-site
               permanent disposal; and

           (5)  On-site  temporary  building storage with off-site
               permanent disposal.

     Several potential Federal and State applicable  or relevant and  appropriate
requirements (ARARs) were identified for the site including:  the EPA Standards
for Remedial Action at Inactive Uranium Processing Sites; the Nuclear Regulatory
Commission Standards  for Protection Against Radiation; the National Historic
Preservation Act;  and the Archeological and Historic Preservation Act.  Action-
specific ARARs were considered  in the course of each remedial alternative.

Description of Selected Remedy

     EPA's preferred   remedial   action   alternative  was   permanent  off-site
disposal.    However,  this alternative was  eliminated during  initial  screening
because it cannot be  implemented  until the  State  of Colorado agrees to  a
permanent  disposal site.  Instead, EPA selected  a remedy that included temporary
on-site building  storage  with  permanent off-site  disposal.   If   a  permanent
disposal facility  becomes available before this  alternative is implemented, EPA
may implement immediately  the permanent off-site  disposal  alternative.
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     The selected alternative involves  the  excavation  and temporary  storage  of
approximately  4,000 cubic  yards  of radium-contaminated  soil from  the  Card
Corporation property.  When a permanent  disposal facility is made available, all
material will be removed from the property and transported to the permanent off-
site disposal  location.   The temporary storage  building and any additions  to
the building may be  dismantled,  decontaminated,  and disposed of in a  sanitary
landfill.   This  alternative  also  includes the  option  of consolidating and
storing radium-contaminated material from other Denver Radium  site properties.
In response to public  concerns,  however, the duration  of  temporary storage  at
the site may not exceed 5 years,  and the maximum amount of material that can  be
temporarily stored is 13,000 cubic yards.

     The selected remedy does not satisfy the statutory preference for treatment
that  reduces  toxicity,   mobility,   or   volume  of  the  hazardous  substances.
Although EPA  evaluated several  treatment technologies,  none were found  to  be
suitable to the site conditions or  the type of contamination present on  the Card
Corporation property.
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                              DENVER RADIUM SITE
              OPEN SPACE PROPERTIES -- OPERABLE UNITS VI, IX, AND XI
                              DENVER, COLORADO

HRS Score: 44.11                                                     NPL Rank: 284

Background

     The Open Space properties portion of  the Denver Radium site  includes three
operable units  (VI,  IX,  and XI)  and consists  of  10  properties  in Denver,
Colorado,  that are contaminated with radium and its associated decay products.
The radium at these properties is believed to have originated from a number of
radium, vanadium,  and uranium processing operations conducted at the  site  in the
1910s and 1920s.  Much of the contamination is the direct  result of radium and
uranium   processing on  the  specific properties or  the  result  of processing
wastes being transported to the property from a processing site.

     After noting a  reference to the  National Radium Institute in a 1916  U.S.
Bureau of Mines  report,  EPA performed field research  in  1979 that indicated the
presence of  31  radioactive  sites  in the Denver metropolitan  area.   In August
1981, the  Colorado Department of Health, under a  cooperative agreement with  EPA,
assumed lead activities  and  initiated engineering  assessments of the majority
of the original 31 properties.  Shortly thereafter, the entire site was placed
on the Interim Priorities List.   EPA resumed Fund lead activities in June  1983
because the  Colorado State  Legislature failed  to  appropriate  the  State  cost
share for remedial  planning  required.  Because of the  enormity of the Denver
Radium site,  EPA divided the  site into 11  operable units,  based upon individual
property  locations   and  conditions.    The  Denver   Radium  site  Remedial
Investigation (RI) report,  which addresses all 11 operable units, was completed
in April 1986.  The draft feasibility study (FS) for the  Open Space properties
(Operable Units VI, IX, and XI)  was released for public review in August 1987.

     A detailed search for potentially responsible parties  (PRPs)  has identified
possible  generators  of radium  contamination  for  many  of   the  Open  Space
properties.   Records indicate that many companies conducted activities related
to the current contamination, but the PRP search has yet  to trace any of these
companies to a  viable,  present-day company.   The  search  has  not revealed any
connection between the current owners  of the  Open  Space properties  and the
activities that caused the respective properties to be contaminated.

Description of Site Work

     During  the RI,  a gamma  radiation survey and subsurface soil samples  were
taken to determine the extent of possible radium contamination at the Open Space
properties.   Soil samples verified  that radium contamination existesd in most of
the properties.   In all  cases where it was  detected, radium concentration  in the
soil  exceeded target  levels established in the  EPA Standards  for  Remedial
Actions at Inactive Uranium  Processing Sites.   The  estimated total volume of
radium-contaminated soil at  the Open  Space properties is  1,458 cubic yards.

     The elevated concentration of  radium  poses  a  health hazard  from three
principal exposure pathways:   (1)  inhalation of  radon  gas,  and  radon's own
short-lived  decay products;  (2) direct gamma radiation exposure  from  the decay


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of radium;  and (3) ingestion  or  inhalation of radium-contaminated  materials.
Because the radium is in a form that is relatively insoluble,  and because it is
not believed that radiological contaminants have migrated into ground or surface
water, potential  ingestion or contact with these media are not  believed to be
major health risks.

Description of Feasibility Study

     In order to mitigate the health risks posed by radium contamination at the
site, the FS developed  several  remedial  action alternatives.   After  an initial
screening  based on  CERCLA criteria,  the alternatives  retained for  detailed
analysis included:

           (1)  No  action  (all  properties);

           (2)  Deferred removal and off-site permanent disposal  (all
               properties);

           (3)  On-site  temporary  land storage and off-site  permanent
               disposal (Allied,   Brannan,  PSCo,   and Thomas  Realty
               properties) ;

           (4)  On-site  temporary  building  storage  and  off-site
               permanent  disposal (Allied,  Brannan,  PSCo,  and Thomas
               Realty properties);

           (5)  On-site   temporary   containment   with   a  Resource
               Conservation and Recovery Act (RCRA)  cap  and off-site
               permanent  disposal (all properties);  and

           (6)  Temporary  building  storage  at  the  Card  Corporation
               property (located  at  Operable  Unit  X)  and off-site
               permanent  disposal (all properties).

     Applicable or relevant and appropriate requirements  (ARARs)  identified for
the site included:   the EPA Standards for Remedial Action  at  Inactive Uranium
Processing  Sites,  the Nuclear  Regulatory Commission Standards  for  Protection
Against Radiation, and  the Executive Order for  Floodplain Management.  EPA also
considered the National Council on Radiation Protection and Measurements and the
International Commission  on Radiological Protection  recommendations  on maximum
gamma radiation in its  analysis of alternatives.

Description of Selected Remedy

     EPA's preferred remedy for the site  was off-site permanent disposal for all
properties with radium contamination (Alternative  2).  However, this alternative
is not  immediately implementable because  the State of  Colorado  has not  yet
agreed to a facility for the disposal of the Denver Radium site wastes and does
not expect  to have  a  disposal facility developed in the  State before  1992.
Therefore, EPA selected a  temporary remedy,  consisting of the following actions:
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          •    On-site temporary capping  of  the  Allied property and
               eventual   excavation   and   off-site   disposal   of
               contaminated soil; and

          •    On-site cleanup of  six  properties;  temporary storage
               of contaminated soil at  the Card Corporation property;
               and   eventual   permanent   off-site   disposal   of
               contaminated soil.

     The temporary measures included in the selected remedy will provide short-
term protection of public health  and  the environment.    The  remedy  is cost-
effective, is  expected to attain ARARs,  and will comply  with EPA's off-site
disposal policy.   A treatment-based remedy was not  chosen for this site because
EPA could not identify an implementable and effective technology to reduce the
toxicity, volume,  or mobility of radioactive wastes.

     In general,  the public supported the selected remedy.  However, the local
community does have reservations  about  any temporary response action because of
the fear that the State will  not make  available  a permanent disposal site for
this material.  In addition,  certain elected officials voiced concerns about
selecting the "no action"  alternative  at  some  of the  properties.   The portion
of  the  community  in  the  vicinity  of  the Card  Corporation  property strongly
opposes temporary  storage  of Open Space material at this property because of the
fear that property values will decline.
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                         ROCKY MOUNTAIN ARSENAL SITE
                         FIRST OFF-POST OPERABLE UNIT
                               DENVER, COLORADO


HRS Score: 58.15                                                NPL Rank: Group 2F

Background

     The Rocky Mountain Arsenal (RMA)  site is located  in Adams County about 10
miles northeast of Denver,  Colorado.  The site covers 27 square miles.  Adjacent
areas  known  as  South  Adams  County  include  farm   land,   with  residential
subdivisions, industrial facilities,  and gravel operations.  The RMA post, which
is owned and  operated by  the U.S.  Army, was  established  in  1942  for  the
production of chemical and  incendiary munitions.  Subsequently, the property was
used to  produce  pesticides and herbicides under  leases to private companies.
Substances  from  both  operations,  as  well as  by-products  and  residues,  were
disposed of on-site.

     Studies  conducted in  one off-post area in south  Adams County  by EPA and
local authorities  indicated  that  concentrations  of volatile  organic compounds
(VOCs),   such  as  1,1-dichloroethane  and trichloroethylene,  were  present in the
ground-water  system.   Other possible  contaminants  include benzene,  vinyl
chloride, and pesticides.   The local  water supply  system serves about 30,000
customers with water from wells  in one portion of the affected alluvial aquifer.

     Various government bodies,  including EPA, sampled the ground  water off-post
and identified the  RMA as  one of three or more  sources of the  contamination.
The EPA lead RMA off-post remedial investigation/feasibility  study (RI/FS) was
initiated in  1985 to  evaluate  measures to abate  the  threat of the off-post
contamination; the Army is conducting  an RI/FS on-post  and  in another off-post
area.    During the course of  its  RI/FS, EPA determined that an  operable unit
should be conducted  to address replacement or treatment of  contaminated ground
water being used for the public water  supply.   Subsequent operable units may
address aquifer restoration and source control  measures.  The ROD for the first
off-post operable unit was signed June 4, 1987.

     In March  1986,  the Army agreed to transfer $1 million to EPA  for use in
responding to the contamination.  The publicly used ground water is currently
being treated prior to consumption through  a temporary carbon filtration system
that will operate until  the  permanent system  selected by the ROD is in place.
The temporary  action is funded by the Army,  and  it  is being conducted by the
local government  through a cooperative agreement with  EPA.   On  September 28,
1986,  the Army provided EPA with an  additional  $6 million for  response purposes
pursuant  to  the  existing  enforcement  agreement  and  on September  16,  1987,
another $300,000 was provided in another amendment.  Under a separate September
18, 1987 agreement,  the Army provided  another $6 million for  the long-term (25
years)  operation and  maintenance  (O&M)  of  the  permanent  treatment  system,
$975,000 for  reimbursement of the private  well connection costs, and $300,000
for the  construction of the  permanent system.   Total Army  funding  thus  far
totals $14.575 million. If EPA identifies other parties potentially responsible
for the  contamination, it will attempt to recover remaining  response costs from
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them.   EPA  may also  seek additional  funding from  the Army,  under  limited
circumstances.

  In 1986  through  1988, all interested  owners  of off-post private wells  were
connected to  the public water system when EPA determined that  contamination in
the  alluvial aquifer  exceeded  Federal  limits  and posed a  threat: to  public
health.

Description of Site Work

     Ground-water sampling results collected from various investigations through
1986 indicated  the presence of large areas of  contaminated water  off-post in
south  Adams   County.   VOCs were  present  in  the  highest concentrations,  and
detectable levels of contamination were noted in municipal wells.   The  off-post
RI indicated that  the contamination was migrating in the ground water  in the
alluvial  aquifer,   the  primary drinking source  for  about  30,000 residents.
Exposure to  VOCs  could result from routine domestic  use of water, ingestion,
inhalation (e.g.,  during showering), and dermal contact.

Description of Feasibility Study

     The  FS  evaluated 10  alternative remedies to   abate   the  threat  of
contamination in the drinking water in the EPA off-post study area.  To  evaluate
the  10 alternatives, EPA  classified  alternatives according  to the extent to
which  a given  alternative would  approach, attain,  or  exceed applicable  or
relevant and appropriate  requirements (ARARs).    The  FS identified a  range of
potential  ARARs,   including  the  Safe  Drinking Water Act   (SDWA)   Maximum
Contaminant  Levels  (MCLs),  Maximum  Contaminant  Level Goals  (MCLGs), Water
Quality  Criteria  (WQC),  and National   Emission  Standards for Hazardous  Air
Pollutants (NESHAPS)  for vinyl  chloride.  EPA also identified  a number of the
State  standards as  ARARs for the  operable unit.   In accordance with EPA policy
at the time of the  FS,  EPA  designated MCLs as the ARARs that the selected remedy
for ground-water remediation must attain.  EPA expects that the MCLs will drive
the design and operation of the remedy.

     EPA   reviewed  the   following   10  alternatives   by  evaluating   their
effectiveness, the  engineering of  the proposed  response approach,  arid  cost:

           (1)  No  action;

           (2)  Alternative water  supply;

           (3)  Air  stripping of VOCs;

           (4)  Air  stripping of potential semi-volatile organic
               compounds;

           (5)  Air  stripping of VOCs with off-gas treatment;

           (6)  Air  stripping of potential semi-volatile organic
               compounds with off-gas treatment;
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          (7)  Granular activated carbon  (GAC) treatment;

          (8)  Air  stripping  with  off-gas  treatment  for  two
               wells; GAC for  five wells;

          (9)  Continued use  of GAC  system  leased for  removal
               action; and

          (10) Blending.

     EPA published  three  fact sheets  on  the site during  1986 and held  press
conferences to keep the public  informed of remedial progress.  EPA also attended
five public  meetings  and  held a public  comment  period on  the draft RI/FS.
Community  reaction  to  EPA's  preferred   alternative  (discussed  below)  was
favorable.

Description of Selected Remedy

     The recommended remedy is a GAC  treatment system with  the regeneration of
spent  carbon (Alternative  7) .   This  cost-effective alternative  effectively
mitigates and minimizes threats to public health.  EPA found the chosen remedy
to be the most favorable when comparing alternatives on the basis  of technology,
reliability, permanency, cost, and effect on the public  health.

     The GAC  system will treat contaminated water from  the  South Adams County
Water and Sanitation District (SACWSD) supply wells prior to its  consumption as
drinking water.   The GAC system will  remove the substances of primary concern
from the drinking water to  levels  that will assure protection of human health
and  attain  ARARs,  The system will  require future  operation and  maintenance
activities to ensure its continued effectiveness.

     In the  event that vinyl chloride  levels  increase above  the standard  and
require remediation, the GAC system will be designed so that an air stripper  may
be added to  remediate the vinyl chloride.  Spent carbon from the GAC system will
be regenerated at an  incinerator  in compliance with  sections  3004  and 3005 of
SDWA.
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                        PHOENIX-GOODYEAR AIRPORT SITE
                           SECTION 16 OPERABLE UNIT
                              GOODYEAR, ARIZONA


HRS Score: 45.91                                                      NPL Rank: 254

Background

     The Phoenix-Goodyear Airport  (PGA) site is located approximately 17 miles
from Phoenix,  Arizona.   In 1981, the  Arizona Department of Health Services
(ADHS)   discovered  that  ground  water  and  18 wells  in  the  PGA  area  were
contaminated by solvents,  chromium and trichloroethene  (TCE).  Drinking water
supplies,   industrial  water  supplies,  and irrigation water  come  solely from
ground water  that is  pumped from the  aquifer  underlying the site  area.   In
addition,   development  by  the  City of  Goodyear  is planned  for  the  area
downgradient from the  site,  and this development will include  using ground-water
resources currently threatened by contamination.  The site was  added  to the NPL
in September 1983.

     An operable unit was initiated  at  the PGA  site based on geography and the
contaminated  media being addressed.   The  aquifer  underlying  the site  is
separated into three units.   Subunit  A of the aquifer is unsuitable for drinking
water.   Subunits B and C of the aquifer are potential sources  of drinking water
and are hydraulically connected.   Subunit  A is  also  connected to Subunits B and
C by conduit  wells and sand lenses.    The  Operable  Unit  addresses the ground-
water contamination of the upper alluvial aquifer in the southern portion of the
site.  This operable  unit covers  750 acres and includes  the Loral Corporation
facility (formerly owned  by the  Goodyear  Aerospace  Corporation [GAG]) and the
Phoenix-Goodyear  Airport  (formerly  owned  by the U.S. Navy).   Both of these
facilities are potential sources  of the volatile organic compound  (VOC) ground-
water contamination.

     The EPA lead Remedial Investigation (RI) for the entire  site was initiated
in 1984.  The feasibility study (FS)  for the Operable Unit was released in the
summer of  1987  and the ROD was signed  September  29,  1987.   Soil and soil/gas
sampling is currently being completed to characterize soil contamination at the
site.  Consequently, soil and ground-water contamination beyond the area of the
operable unit will be  addressed in the  subsequent FS for  the entire  site.

      EPA  identified  GAC and the  Department of Defense  (DOD) as potentially
responsible parties (PRPs) at the  site.  GAC has been participating in the RI/FS
process since 1984, and an Administrative  Order for  RI/FS  activities  was signed
by GAC and EPA in March 1986.  The U.S. Corps of Engineers represented the DOD
on the Phoenix-Goodyear Airport Interagency Committee, which  was established by
EPA  to  involve State and  local  agencies,  as well as PRPs,  in actions  on the
site.
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Description of Site Work

     The RI examined ground-water  contamination in Subunits A,  B, and C of the
aquifer.   In addition  to  TCE and chromium contamination,  elevated levels of
compounds  including 1,1-dichloroethene,  chloroform,  and  carbon tetrachloride
were detected in the ground water at the site.  Those identified as potentially
affected by contamination were wildlife near  the site and the population of the
Goodyear/Avondale area.  Four endangered species inhabit or migrate through the
area just south of the site.  Additionally, the PGA area itself supports one of
the largest  breeding dove  colonies  in the Southwest  and is popular  for dove
hunting.  The RI determined that risk  associated with exposure to contaminated
ground water  is  an excess  lifetime cancer  risk as  high as 2 x 1CT3.   Although
exposure to contamination is currently  limited,  future migration of contaminants
will present heightened risks.

Description of Feasibility Study

     The purpose of the  FS for  the  Section 16 Operable  Unit  was  to  remove
contaminants  from  the  ground-water  system  and  to  limit  the  migration  of
contaminants from  Subunit  A of the aquifer to  Subunits B  and C.   The detailed
evaluation of alternatives considered CERCLA requirements that a remedial action
protect human health and   the  environment and permanently  and  significantly
reduce the volume,  toxicity,  or mobility of  hazardous  substances,  pollutants,
or contaminants.   The remedy selected  for  the  Section  16  Operable  Unit should
also be consistent with the  final remedial  action  for the entire  site.   The
alternatives considered were grouped into three  categories:  ground water, water
treatment,  and water end use.

     (1)  Ground-water Alternatives:
          •    No action;
          •    Containment  with a  slurry wall;
          •    Extraction  at GAG and PGA facilities;
          •    Extraction  from Subunit A beneath all of  Section 16;
               and
          •    Extraction  from Subunit A,  at  an accelerated rate.

     (2)  Treatment Alternatives:
          •    Air stripping;  and
          •    Carbon adsorption.
               (All other treatment alternatives were screened out due
               to  performance  or  institutional  constraints   and
               inability    to    treat    expected    contaminant
               concentrations.)

     (3)  Water End-Use Alternatives:
          •    Ground-water recharge.
               (All other water end-use alternatives were screened out
               because of  the high concentrations  of  total dissolved
               salts in Subunit A water.)
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     Federal applicable or relevant and appropriate requirements (ARARs) for the
site included  the Safe Drinking  Water  Act  (SDWA)  Maximum Contaminant  Levels
(MCLs)  and Maximum Contaminant Level Goals (MCLGs).

     EPA held a public comment period and a public meeting,  and distributed fact
sheets concerning the site.  During the  public comment period on the FS in June
and  July 1987,  EPA  received comments  from  persons residing  or  conducting
business in the area  of the site.

Description of Selected Remedy

     The entire  Subunit A of Section 16  will be pumped  and treated with  air
stripping and reinjected  into the aquifer.  Water from Subunit  B  and C will be
pumped  and  treated by the Loral  Corporation at  historical  rates that  have
contained the  contamination  within Subunit B  and  C.   Treatment  will  continue
until contaminant levels  of the discharge from the  treatment  plant  meet ARARs.
Emissions controls, such  as activated carbon units, will be used to  treat  air
releases from the treatment facilities,  and if the carbon is taken off site, it
will be disposed of at an  approved Resource Conservation and Recovery Act (RCRA)
facility.

     The selected remedy satisfies the requirement of reducing  the  mobility,
toxicity, and volume  of contaminated water.  It also uses  a  treatment technology
to the maximum extent practicable in a cost-effective manner.   The remedy meets
the operable unit goals of stopping the migration of  contaminants,  is  expected
to meet  ARARs,  and  fulfills the preference  for  permanent solutions  at CERCLA
sites.
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                    OPERATING INDUSTRIES INC. LANDFILL SITE
               SITE CONTROL AND MONITORING (SCM) OPERABLE UNIT
                          MONTEREY PARK, CALIFORNIA

HRS Score:  57.22                                                      NPL Rank:  71

Background

     The Operating Industries  Inc.  (Oil)  site consists of a 190-acre landfill
located approximately 10 miles east  of Los Angeles in Monterey Park, California.
During  its  operation from  1948  to  1984,  the  landfill accepted municipal and
industrial waste.   Leachate generated  at the  site contains hazardous organic
compounds including  vinyl chloride, trichloroethylene,  benzene,  and toluene.
There are approximately  53,000 residences within a 3-mile radius of the site.
The site  is  owned by Operating Industries  Inc.,  the  former operators  of the
landfill.   EPA has been conducting site control and monitoring  (SCM) activities
at the site since May 1986 when Oil discontinued all activities at the site.

     Hazardous  wastes  accepted  at  the   landfill  included  water-insoluble
nondecomposable inert solids, waste-water treatment sludge  from the production
of chrome oxide green pigment,  and slop  oil  emulsion solids  and tank bottom
sludges (leaded)  from petroleum  refining operations.    Both landfill  gas and
leachate  are   generated  at  the  site.    Leachate  collected by  the  leachate
collection system was historically  mixed  with solid wastes on site but, since
1985,  has been transported by EPA to a  permitted off-site treatment facility.

     Oil  was  responsible  for installation  of a  leachate  collection system,
development of an air-dike injection system to control subsurface gas migration,
installation of gas extraction  wells   around  the  perimeter of the  site,  and
limited site contouring and covering.   Emergency actions taken by EPA included
slope stability and  erosion control improvements,  surface runoff and drainage
improvements,   and site  security.   In  addition, the perimeter of the  southern
portion of the landfill was fenced, entrance   restricted, and 24-hour security
provided.

     EPA signed two RODs for continuing site control and monitoring activities
as  an  interim  remedy   until  a  long-term  solution  is  developed,  and  for
construction of an on-site leachate  treatment plant.  Long-term remediation will
be  addressed  in  a  comprehensive  remedial  investigation/feasibility  study
(RI/FS).  An additional operable unit  FS is  currently underway for gas control.
EPA is conducting negotiations with the Oil  potentially responsible party (PRP)
steering committee to have  the  PRPs conduct and finance RD/RA of the leachate
treatment plant and daily site control.

Description of Site  Work

     Although the RI for the site has not been completed, numerous  site problems
include the  following:    hazardous  leachate  seepage  and breakthrough  on the
landfill slopes; subsurface and off-site  migration of leachate; high landfill
methane  levels;  vinyl   chloride  present  in  ambient  air  emissions  and   in
subsurface gas  on site and off site;  underground fires and associated subsidence
on site; slope  instability  and erosion problems;  surface runoff;  ground-water
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contamination  from  leachate  and migrating landfill  gas;  and  noxious  and
offensive odors both on site and  off site.

Description of Site Control and Monitoring Feasibility Study

     Seven control systems require operation and maintenance (O&M),  inspection,
and monitoring activities, as addressed in  the  SCM operable unit:   (1) the gas
extraction and air dike system; (2) leachate collection system;  (3)  irrigation
system;  (4)  access  road  system;   (5)  storm water drainage  system;  (6)  site
security; and (7) slope repair and erosion control.  Initial screening narrowed
the detailed alternative evaluation to two  remedies:

          (1)  Full-time  SCM (Level  1) -  continued SCM  of the
               site  systems,  limited to   O&M  of  the  systems
               currently in place; and

          (2)  Full-time SCM (Levels  1 and 2) - continued SCM and
               improvements  to the systems.

Level 1 is considered  a baseline  level consisting of basic  repairs,  and Level
2 includes preventative maintenance.

     Community involvement  at the site  included  formation of a committee of
residents who  live near the landfill.  Additionally,   EPA  conducted community
interviews,  established information repositories,  distributed fact  sheets, and
held public  meetings to keep  the community on-site  activities and to discuss the
SCM and leachate management  FSs.

Description of Selected Remedy

     EPA recommended Alternative  2 for site control monitoring:   full-time SCM
(Levels 1 and 2)  .  This alternative is more protective of public health and the
environment than Alternative 1 because it  allows  for  system  improvements, is
protective  of human health  and  the  environment,  cost-effective,   and  uses
permanent  solutions   and  treatment  technologies   to  the  maximum  extent
practicable.  The  recommended alternative  is not expected to achieve ARARs for
gas emissions  but, because  it  is an interim remedy,  this requirement  can be
waived under CERCLA section  121(d).
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                        SAN FERNANDO VALLEY AREA 1 SITE
             NORTH HOLLYWOOD/BURBANK WELL FIELD OPERABLE UNIT
                        LOS ANGELES COUNTY, CALIFORNIA

HRS Score: 4224                                                      NPL Rank: 343

Background

     The  North Hollywood/Burbank Well  Field is  located in  the  San Fernando
Valley Area  1  site,  one  of four NPL sites in the  112,000-acre  San Fernando
Valley ground-water basin.   The ground-water basin is situated in the coastal
mountain  ranges  within the  Los Angeles Metropolitan area.    The  Los Angeles
Department of  Water and  Power  (DWP)  operates the well  field, which provides
approximately  10  percent  of DWP's total water supply to the  residents of the
City of Los Angeles.   Ground water  from the basin can supply water to as many
as one million people  and is also an important source of water for the nearby
cities of Burbank, Glendale, and San Fernando.  Three other well field sites in
the basin  (known  as San Fernando Areas  2,3, and  4)  have also been included on
the NPL.

     Investigation of contamination in the Area 1  well field began  in  1980 with
the  discovery  of  trichloroethylene   (TCE)  and  tetrachloroethylene  (i.e.,
perchloroethylene or PGE) in one-quarter of DWP's wells  in the basin.  In July
1981, DWP  and  the Southern California Association of Governments  (SCAG) began
a  2-year  study  funded by  EPA.   The  study revealed that  contamination was
spreading with the flow of ground water at  a rate of  nearly 300 feet  per year.
Consequently,  DWP began a program  that involved pumping and  dilution of the
contaminated water to control the spread of contamination.  In  1984, the entire
Area 1 site, along with the three other well  field  sites  in the San Fernando
Valley basin, were proposed  for  inclusion on the NPL.

     In 1985,  EPA evaluated site data and concluded  that adequate information
existed to justify a Fast-Track  evaluation  of the North  Hollywood/Burbank Well
Field.  In March  1986, under a  cooperative  agreement  with EPA, DWP prepared an
Operable  Unit  Feasibility  Study (OUFS)  to recommend  an  interim  remedy for
mitigating ground-water migration  in Area 1.    The ROD  for the  well  field
operable   unit  was   signed  August  31,   1987.     A  comprehensive  remedial
investigation/feasibility study  (RI/FS) of  the entire San Fernando Valley area
is being completed to select a  final  remedy for all four sites.

     EPA developed a list of 59  potentially responsible  parties (PRPs) for the
four  sites within  the  San Fernando Valley.    The  PRP  facilities  included
electroplating, aircraft,  and light manufacturing industries.   EPA plans to send
CERCLA  section  104  information-gathering  letters   to  these facilities  to
determine  the extent of their responsibility.

Description of Site  Work

     Because the  OUFS for  the  Area 1  well field was completed prior  to the
comprehensive  RI/FS,  the  extent of  contamination  was  based on  preliminary
investigations.  The RI for all  four  San Fernando Valley sites began  in August
1987.  According  to  the investigations, TCE is the  primary  contaminant,  with
lesser quantities of  PCE  and other volatile organic  compounds present in the


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ground water.  The highest TCE level found  (1500 ppb)  is  300  times  the  Federal
standard for the contaminant  (5 ppb).

     Presently,  water from  the  27  wells  in  the  North  Hollywood  Well  Field
contain TCE  in levels  greater  than Federal  and  State standards  and,  at  the
current  rate  of  migration,  water  from  another  5  to  10  wells  may  exceed
contaminant levels in the next 2 years.  Under normal  conditions, ground water
delivered to DWP customers does contain TCE and PCE, but  at levels  that do  not
exceed Federal and State standards.  During  periods of drought and high  demand,
however, DWP may be forced to provide water that exceeds  standards.

Description of Feasibility Study

     The objective of the operable unit FS was to  identify actions to  slow down
or arrest the migration of the contaminant plume at the North  Hollywood/Burbank
Well Field.   The  selected alternative was to be used as an interim measure while
the  comprehensive  RI/FS  is  performed.     After   an initial  screening   of
technologies  and alternatives  based  on cost and  effectiveness  in  meeting
operable unit goals, three alternatives were  retained  for detailed  evaluation:

          (1)  Ground-water extraction and treatment by aeration;

          (2)  Ground-water extraction and treatment by granular
               activated  carbon (GAG); and

          (3)  Ground-water extraction and treatment by aeration
               combined with vapor-phase GAG.

     In December 1986, EPA and DWP held a community  meeting on the  OUFS report
with approximately 15 residents in attendance.

     Federal ARARs identified for the site  included the Safe Drinking  Water  Act
(SDWA) Maximum Contaminant  Level  Goals (MCLGs) and Maximum Contaminant Levels
(MCLs).   The MCLs  for  TCE  and  PCE were determined to  be applicable  to  the
remedial action.   State ARARs included California State Action Levels,  which
generally parallel EPA's MCLs and MCLGs.  Resource Conservation and Recovery  Act
(RCRA)  standards for disposal  of  spent  carbon will  be  considered  an  ARAR.
Alternatives will comply with State air-quality standards  set by the  South Coast
Air Quality Management District in Los Angeles.

Description of Selected Remedy

     EPA determined that the most cost-effective  interim remedy is ground-water
extraction  and  treatment  by  aeration,   combined  with vapor-phase   carbon
adsorption  (Alternative  3) .   Although  all  three  alternatives were considered
capable of  meeting  ARARs and CERCLA  requirements  that a remedy protect  human
health  and  be technically  implementable,   public  concern over  air  emissions
caused EPA to select aeration with carbon adsorption as a remedy.  The aeration
facility will be constructed by the DWP under a cooperative agreement  with EPA.
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                            SAN GABRIEL AREA 1 SITE
                           INITIAL REMEDIAL MEASURES
                             EL MONTE, CALIFORNIA

HRS Score: 4224                                                    NPL Rank:  341

Background

     The  San  Gabriel Area  1  site is  one of  four  sites  (Areas  1  through 4)
located in the San Gabriel ground-water basin in Los  Angeles County, California.
All four  sites were found to have contaminated ground  water with chlorinated
hydrocarbons.    Area 1 contains a plume  of  ground-water contamination located
primarily underneath the City of El Monte.

     In  1980,  the State of  California began  an  extensive well-water testing
program in the  San  Gabriel basin.  Results  indicated that numerous wells were
contaminated   with   trichloroethylene   (TCE),   tetrachloroethylene   (i.e.,
perchloroethylene or  PCE), and  other  chlorinated hydrocarbons.   Although many
water companies have been affected by the contaminated water, only three small
water companies in the City of El Monte have been unable to provide water that
meets Federal  and State  drinking-water standards.  The  larger water  companies
affected by the contamination have taken interim actions, such as  shutting down
the contaminated wells or blending water,  to reduce  contaminant concentrations.
The  three water  companies,  Richwood,  Rurban Homes,  and  Hemlock,  have  no
alternate water supplies.

     A  Focused Feasibility Study  (FFS)   that  was completed  in  December 1983
identified an  initial remedial  measure (IRM)  to  resolve the water companies'
contamination problem before a long-term solution to ground-water contamination
in the San Gabriel basin is implemented.  The objective of the IRM was  to  ensure
that all  residents  affected by  ground-water  contamination in San Gabriel Area
1 are provided  with  safe drinking water.     A ROD signed in May 1984 selected
air-stripping treatment as the most cost-effective IRM for  the three companies.
During a  Pre-Design  Study  initiated in July  1984, however, it became apparent
that the cost  to construct  the remedy would be much higher than estimated  in the
FFS.    Consequently,  the conceptual design and costs for  the next  most cost-
effective alternative, carbon adsorption  treatment,  were revised.

     In October of 1985, the California State Assembly passed Senate  Bill 1063
authorizing State funding  for treatment  systems  and  directing  the California
Department of  Health Services  (DHS) to pay for the carbon adsorption systems for
20 years.   The bill  allowed EPA to  reconsider  its decision  regarding  the
feasibility of  the carbon adsorption alternative due  to its high operation and
maintenance (O&M) cost.

     DHS used  State  funds to  construct  an  emergency  connection from Richwood to
the San Gabriel Valley Water Company in early 1986.  Conceptual designs and cost
estimates for  carbon adsorption systems were completed,  and cost estimates for
the air-stripping alternative were updated  in June 1986.   Given the  new cost
estimates, EPA  determined  that  carbon adsorption was the  most  cost-effective
alternative.   The ROD for the IRM at Area 1 was signed September 30,   1987.   An
overall area-wide remedial investigation/feasibility  study (RI/FS) for the San
Gabriel Area (Sites 1 through 4) is being conducted.


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Description of Site Work

     Sampling studies in Area 1 indicated that  the contaminant  level  of PCE  in
the Richwood Mutual Water  Company North Well was approximately 25 times  State
action levels and, since that time, Richwood's  wells have been  shut down.  The
Rurban Homes Mutual Water Company's wells showed PCE concentrations just  above
DHS action levels in January 1985.  Monthly sampling in 1987,  however,  has since
detected PCE levels below  action  levels;  the reason for this drop is  unknown.
Sampling data for 1987 shows PCE levels  in Hemlock's two wells ranging  from less
than 10 ppb to as high as 150 ppb, far  above the recommended limit of 1 ppb.

Description of Feasibility Study

     The IRM alternatives presented in  the 1984 ROD were:

           (1)  Treatment of well discharge with air-stripping system;

           (2)  Dissolution of water companies and merger with another
               water company;

           (3)  Provision of bottled water;

           (4)  Connection to metropolitan water district; and

           (5)  Treatment   of   well   discharge  with  carbon
               adsorption.

     Further evaluation of the alternatives  and the  development  of more refined
estimates of water use, has  led to cost-estimates different from  those  initially
identified.  The non-cost factors associated with each of the IRM alternatives
were also  reevaluated.

     Federal  applicable  or  relevant  and   appropriate requirements  (ARARs)
identified for  the site  include  the  Safe  Drinking Water Act  (SDWA)  Maximum
Contaminant Level  Goals  (MCLGs)  and Maximum Contaminant  Levels  (MCLs).   Also
taken into consideration were Health Advisories  issued by EPA Office  of Drinking
Water and  DHS action levels.  ARARs for the air-stripping alternative included
State Air  Quality Management Rules  and  the  Clean  Water Act  (CWA)   National
Pollution  Discharge Elimination System (NPDES).  State Air  Quality Management
Rules were also an ARAR for  the carbon  adsorption alternative.

     A public comment period on  the draft report for  the IRM was scheduled  in
October 1986.  A fact sheet on the report was distributed and the report was
made  available   at  three  information  repositories.    No  public meeting was
scheduled  during the public comment period;  however,  two comments  were received
on the selection of alternatives.
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Description of Selected Remedy

     On  the  basis  of  the  revised cost-effectiveness  analysis,  EPA  selected
carbon adsorption treatment of well discharge from Richwood and Rurban Homes as
the IRM alternative (Alternative 5).  The remedy, which also includes upgrading
Hemlock's  current  carbon  adsorption  system,  was  selected  because  it  is
protective of human health  and the  environment and meets  the  CERCLA preference
for treatment technologies.  Under  this alternative, the financial impact on the
water companies' water  users  is  mitigated through the  State's  funding of O&M.
The alternative presents less  potential visual  and noise impact on the community
than  other options  and, continued use  of the  water companies'  wells,  may
contribute to reduced migration of  contamination in the ground-water plume.

     Due to the recent drop  in contamination levels in Rurban Home's wells,  the
treatment  system will not  be implemented  if  continued  monitoring shows  the
contaminant levels remaining below  action levels.   In addition,  in  response to
a request by Hemlock, its present system will  not be  upgraded at  this  time.
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                            STRINGFELLOW ACID PITS
                         EARLY IMPLEMENTATION ACTION
                             GLEN AVON, CALIFORNIA

MRS Score: 61.40                                                     NPL Rank:  32

Background

     The Stringfellow Acid Pits site is a hazardous waste  disposal facility  in
Riverside County, 5 miles northwest of  Riverside,  California.  The Stringfellow
Quarry Company operated the facility from August 1956  to November 1972, when  it
was voluntarily closed.  During operations,  the company deposited approximately
34  million  gallons  of  industrial  wastes,  primarily  from  metal  finishing,
electroplating and DDT production,  in evaporation ponds  over 17  acres of the
site.   Site  operations  also included  spray  evaporation  of  pond  contents  to
accelerate volume reduction.   In  1969  and  1978, excessive rainfall caused the
disposal ponds to overflow.   The  overflows  extended across a highway into the
nearby community of Glen Avon.

     In  1980 and 1981,  the  Santa  Ana Regional  Water Quality  Control Board
(RWQCB) implemented an Interim Abatement Program,  including removal of liquids,
capping, and installation of monitoring wells  and a leachate collection system.
In 1983, EPA  initiated a "Fast Track" remedial  investigation/feasibility study
(RI/FS)  to  identify  alternatives  for ground-water  extraction  and  off-site
disposal.  The selected interim remedy  included the installation of an on-site
treatment facility and additional  interceptor and monitoring wells.   The ROD for
the interim remedy was signed July 1984.

     The  California Department  of  Health  Services  (DHS)   is  conducting a
complete RI/FS  to  identify and evaluate alternatives for final site cleanup.
The  FS  report  is  expected  to  be completed  by mid-1988.   EPA and  DHS have
identified two early  implementation  actions (EIAs)  to be conducted before the
comprehensive RI/FS is completed.  The decision on the EIAs was presented in the
ROD signed June 25, 1987.

     In April 1983, EPA and  the State of California filed  a civil suit in U.S.
District  Court  against  18  generators  of   the  Stringfellow  wastes,  four
transporters, and nine owners and operators of  the disposal facility.  EPA has
given these potentially responsible parties  (PRPs) the opportunity to design and
implement the EIAs subject  to EPA and  DHS  approval and oversight,  but has not
been successful in reaching  an agreement with  any of  them.

Description of Site Work

     The 1984 EPA lead RI  revealed that  ground water beneath the site is heavily
contaminated with metals, sulfates,  nitrates,  fluoride,  chloride, and a variety
of organics.  Ground-water samples also indicated elevated levels of radiation,
although no  relationship has been  found between the Stringfellow wastes and
radiation  in private  community wells.   Most  recent  RI activities Indicated a
zone of  contamination  900  feet  wide,  extending 2 miles downgradient from the
site.  Additional ground-water monitoring detected site-related contaminants  in
a plume  moving  downgradient from the site  into the  lower canyon area and the
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Glen Avon community, indicating the need for additional actions to increase  the
effectiveness of the current interim measures.

     The primary concern is human exposure to ground water through consumption.
If the contaminant  plume spreads further into the downgradient regional aquifer,
it  could  contaminate  the drinking  water supply  wells  in  Glen  Avon  and
surrounding areas  as well  as  those wells used for industrial  and agricultural
purposes.   Another  significant  exposure potential  is  through  contact with
surface water on site and with upgradient water running on the site,  especially
during  large  storms.   This exposure  potential is  limited although it can be
decreased further  by  improving surface  drainage,  especially  in the  upgradient
areas.

Description of Feasibility Study

     Based on the initial findings of the RI, the following objectives have been
identified for the final remediation process:

          •    Prevent  further plume  migration and contamination by
               isolation   and/or   treatment   of   the   contaminated
               soil/water mixture;

          •    Redirect  runoff and run-on  to  prevent  surface-water
               contamination;

          •    Prevent  site air  emissions that may adversely  affect
               public health or the environment;  and

          •    Manage the site area to prevent direct  contact.

     DHS performed an  assessment of  86  potentially applicable  technologies.
Remaining technologies  were compiled  into remedial action alternatives,  which
were screened for compliance with CERCLA requirements and the above objectives.
Except  for  the  "no action"  alternative,  all  of the  remaining  alternatives
included the following  two actions:

          (1)  Diversion of upgradient surface waters by means of  new
               peripheral channel; and

          (2)  Mitigation of  the  downgradient contaminated plume  by
               installing a ground-water barrier  system;

These actions, which should be implemented as soon as possible, were  designated
as potential EIAs.   Also considered as a potential EIA was the following action:

          (3)  Alternative  2,  with  treatment  of  extracted  ground
               water.

     DHS identified Clean Water Act (CWA) discharge requirements  and Santa Ana
Watershed Project  Authority  (SAWPA)  pre-discharge  treatment requirements as
applicable or relevant and appropriate requirements  (ARARs)  for the  site.
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     Although no comment was  received from the public regarding  selection and
implementation of the EIAs,  the EIAs are consistent with  prior remedial actions
that the community has  supported.  Several public meetings have been held during
the ongoing RI/FS process.

Description of Selected Remedy

     The EIAs selected for  the site  are Alternatives 1 and 3,  which include the
following actions:

          •    Installation of a peripheral channel  around  the north
               end of the original site to  direct  upgradient surface-
               water runoff; and

          •    Installation of  a.  ground-water barrier system  in  the
               lower canyon  area  and  treatment  of extracted  ground
               water, if necessary,  with discharge to a publicly-owned
               treatment works.

In addition, based on  the  July 1984 ROD,  the  existing water  channels  will be
extended southward to discharge surface water  to  Pyrite  Creek.

     These  actions will increase the effectiveness  of  the existing  remedial
system and are consistent with both  past actions  and the  final remedial actions
to be chosen after completion of  the comprehensive RI/FS.  These  actions  have
community support, have no significant  adverse environmental  effects,  and  will
help to protect public health and the  environment.   The  State  concurs  with the
remedy.
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                             COLBERT LANDFILL SITE
                             COLBERT, WASHINGTON


MRS Score: 41.59                                                     NPL Rank: 356

Background

     The Colbert Landfill is a 40-acre sanitary landfill located in the  town  of
Colbert approximately 15 miles  north-northeast of Spokane, Washington. The area
is semi-rural with a population of about 1,500 people within a 3-mile radius  of
the landfill.  Since 1968,  the  landfill  received both municipal  and  commercial
wastes until it was filled to capacity;  it is no longer receiving waste.   During
the years  from 1975 to  1980,  a local  electronics  manufacturing company, Key
Tronic Corporation, dumped spent organic solvents  at the site,  mainly methylene
chloride  (MC)  and 1,1,1-trichloroethane (TCA), at  an average rate  of  several
hundred  gallons  a month.  During  the  same  period a nearby military facility,
Fairchild Air Force Base, also  disposed  of  various  solvent wastes  at the site.
Other parties that disposed  spent  solvents  at the site may be  identified.

     In  1980, following  complaints by  nearby  residents of chemical disposal  in
the landfill, the Spokane County Utilities Department initiated an investigation
and  sampled nearby private wells.   Results indicated that  some  wells  were
contaminated with  TCA.   The Phase  I  study of the Spokane County investigation
recommended  a  ground-water  monitoring program,  based on a review of existing
information on the site  and  field  study.  Phase II  studies carried out  in 1982
involved  installation  of monitoring wells,  injection tests,  and  ground-water
sampling and analysis.   In August 1983, EPA placed the Colbert Landfill  site  on
the National  Priorities List  (NPL).   The  EPA  identified  Spokane  County, Key
Tronic Corporation and  Fairchild Air  Force Base as  potential  responsible parties
(PRPs) .

     The remedial investigation/feasibility study  (RI/FS), jointly  conducted  by
the Washington Department of Ecology and EPA,  was completed in May  1987.  The
ROD signed September 20, 1987 selected an interim  final remedial  action  for the
site, because extraction and interception well-systems will be in operation for
decades before remediation  is complete,  and changes  in the selected  action may
be required during that  period.

Description of Site Work

     The main contaminants detected  in the  ground water  during the RI were six
volatile organic chemicals.   The only contaminant  of concern detected in any  of
the soil  samples  was MC.  Detectable  levels  of "soil gas"  contamination  were
found over much of the  area where  ground-water  contamination had been found.
The RI results suggested that substantial quantities  of  contaminants remain  at
the bottom of the  aquifers in the form of dense,  nonaqueous phase  liquids,  i.e.,
relatively  undiluted  chemicals existing as  separate liquids rather than  in
solution in the ground water.
                                      351
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


Description of Feasibility Study

     Three remedial alternatives were developed and evaluated in the FS:

           (1)  No action;

           (2)  Alternate water supply,  point of entry  treatment,
               and ground-water extraction;  and

           (3)  Treatment    and   discharge    (using   various
               technologies  for  each)  plus an  expanded water
               system.

     Each  of these alternatives was  considered separately in three  geographic
portions of the  site;  the  southern area,  where the plume in  the  upper aquifer
is advancing;  the  western area,  where  the plume in  the  lower aquifer is  the
major concern;  and the  eastern  area,   where the plumes  appear  to  originate,
probably from accumulations of concentrated solvent fluids.   About 90 different
technologies were  screened  and evaluated,  resulting in detailed  evaluation of
12 remedial alternatives  in the southern  area, seven in the  western area,  and
seven in the eastern area.

     The major Federal  applicable  or  relevant  and  appropriate  requirements
(ARARS)   identified include the  following:   the  Resource  Conservation  and
Recovery Act  (RCRA),  the Safe Drinking Water  Act  (SDWA),  the Clean Water  Act
(CWA),  and the  Clean  Air Act  (CAA).   In  addition,  the selected  remedy has to
satisfy  numerous  Washington  State  laws   and  regulations   that  have  been
identified.  The FS showed that all of  the deep-well extraction,  treatment,  and
disposal alternatives are acceptable,  as long as  performance  standards are met.

Description of Selected Remedy

     This  interim  final  remedial  action addresses management  of  the migration
of contaminants  using a ground-water interception  system in  the  southern  and
western  areas,  and  attempts  source   control  in  the  eastern  area  through
extraction of  ground  water with the highest contaminant concentrations.   All
extracted  water  will  be  treated  to  specified performance standards,  monitored
to assure  compliance, and properly discharged.  The remedy is designed:

     •     to prevent  further spread  of contaminated ground water in
           two aquifers by installing  and operating interception wells
           and treating the  extracted ground  water;

     •     to remove contaminated materials by installing and operating
           extraction wells in the  area where the  plumes originate and
           treating the effluent; and

     •     to provide an alternate water  supply system to any residents
           who  are  deprived  of their  domestic supply by demonstrated
           contamination from the landfill or due  to the action of the
           extraction systems.
                                      352
-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1987


     In order to provide the potentially  responsible parties a sufficient degree
of  latitude  in  selecting  a  technology  required  to  achieve  the  desired
performance,  the ROD did not  specify a particular  technology.   This  desired
performance is defined  as treating wastewater  effluent  to or below  the  Maximum
Contaminant Levels (MCLs),  or a similar health based level (the 1CT6  risk level
for  carcinogens) for contaminants  for  which  MCLs have  not been  determined.
Treated  water  effluents  will  also  be  monitored  to  assure   adherence  to
performance standards.  Treated water discharge shall at all times be consistent
with Federal and Washington State laws.

     The selected alternative meets  CERCLA  requirements because  it  permanently
reduces the  toxicity, mobility, or volume  of  the contaminants.   The selected
alternative  also  is expected  to  meet ARARs,   is  cost-effective,  and  uses
permanent remedies and  treatment to  the  maximum extent practicable.
                                     353
-------
                  Progress Toward Implementing Superfund:  Fiscal Year 1987
                                   APPENDIX D

STATUS OF ACTIVE REMEDIAL INVESTIGATIONS/FEASIBILITY STUDIES AND REMEDIAL ACTIONS
                         IN PROGRESS ON SEPTEMBER 30, 1987


 Columns 1-4 are  self explanatory.

 Column 5:  Lead -      The entity leading the project, i.e., Federal lead by the
                        EPA remedial program and Fund-financed (F);  lead by the
                        EPA. enforcement program (FE); Federal facility lead (FF) ;
                        State  lead and Fund-financed  (S);  State enforcement lead
                        (may include Federal financing) (SE); joint Federal-State
                        lead,  joint  State-PRP lead,  or other combination (JT) ;
                        potentially  responsible  party  lead and financed (PRP).

 Column 6:  Actual Start -The actual date  on which the  listed activity began.
 Column 7:   1/1/87
 Estimated Completion
  Column  8:  9/30/87
  Estimated Completion -

  Column  9 :  Status -
The estimated year and quarter of completion
as  of  January  1,   1987,  unless  otherwise  indicated.
Completion dates followed by  "j"  and "a" were estimated
in June and August 1987,  respectively.  EPA acknowledges
that  using  the January 1,  1987  reference  date  may not
account for all the time gained or lost  in the life cycle
of a given project.  However,  EPA chose the January date
because it marked the first complete  update  for RI/FS and
RA   projects   after  the  hiatus    between   Superfund
authorizations.   Choosing  an earlier  date  would have
included  time   lost  due  to  circumstances  beyond EPA's
control.

The estimated year and quarter of completion
as of September 30,  1987,  the end of the fiscal year.

Status of the activity as of the end of FY87.  On-schedule
activities   are  designated   by  an equal  sign  (=) .
Activities behind  schedule  are designated  by a numeral
indicating the number of quarters the activity is behind
schedule and a minus sign  (e.g., 2-);  activities ahead of
schedule by  a  numeral and a plus sign  (e.g.,  2+).  For
example, at  the end of the fiscal  year, the RA at the
Kellogg-Deering Well Field site in Norwalk, Connecticut,
was  6 quarters  (6+)  ahead  of its  originally scheduled
first quarter  1990  completion date.   An asterisk in the
comment column indicates an activity for  which no estimate
was made prior  to  the estimate at  the end of the fiscal
year.
                                       354
-------



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-------
                                  APPENDIX E

                       EPA FEDERAL REGISTER SUPERFUND
                           DOCUMENTS IN FISCAL 1987
     The daily  Federal Register provides  a  uniform system  for publishing Federal
agency documents.  During the fiscal year, the EPA Superfund program published
32 documents  in the  Federal Register.   These  included  such  things  as proposed and
final rules, notices of public meetings,  and policies with requests for comments.
The following table provides the date, citation, and subject for  each of those
publications for the period October 1, 1986 through September 29, 1987.
Date

1.  Dec. 22

2.  Jan. 22
3.  Feb. 5
4.  Feb. 25
5.  Mar. 16
6.
7.
8.
Mar. 16


Apr. 9


Apr. 17
              Citation

              51 FR 45767

              52 FR 2492
              52 FR 3699
              52 FR 5578
9.  May 13
              52 FR 8140
52 FR 8172
52 FR 11513
52 FR 12866
              52 FR 17991
Subject

Reportable Quantity Adjustments.  Correction.

Amendment  to the National Oil and Hazardous
Substances Contingency Plan; the  National
Priorities List (NPL) , Update //6.   Proposed
Rule.

Limitations  to Superfund Response  Claims.
Notice of  Regulatory  Limitations.

Uncontrolled    Hazardous   Waste    Sites;
Availability  of Documents and  Information
generally  available in PAs and Sis.  Notice
of Availability of  Information.

Hazardous  Substances  Reportable  Quantity
Adjustments.   Proposed Rule.

Hazardous  Substances  Reportable  Quantity
Adjustments.   Proposed Rule.

Intent to  Revise the Hazard Ranking System.
Advance Notice of Proposed Rulemaking.

Notice  of the  First  Priority   List  of
Hazardous  Substances that will be the Subject
of Toxicological Profiles.

The   NPL   Listing    Policy   for   Federal
Facilities.   Proposed Policy.
                                      386
-------
                 Progress Toward Implementing Superfund: Fiscal Year 1987
                        EPA FEDERAL REGISTER SUPERFUND
                           DOCUMENTS IN FISCAL 1987
                                   (continued)
Date

10.  May 28



11.  June 5



12.  June 8



13.  June 10



14.  June 12
15.  June 30
16.  July 7
17.   July 13
18.   July 13
19.   July 20
Citation

52 FR  19919



52 FR  21367



52 FR  21648



52 FR  22244



52 FR  22525
52 FR  24333
52 FR  26160
52 FR  26160
52 FR  26181
52 FR  27257
Authority

 Interim    Guidelines    for    Non-Binding
 Preliminary  Allocations of  Responsibility
 (NEAR).  Request  for  Public  Comment.

 Science Advisory Board, Hazard Ranking System
 Review Subcommittee; Open Meeting, June 29-
 30,  1987.

 Notice   of   the  First  Priority  List  of
 Hazardous Substances that will be the Subject
 of Toxicological  Profiles.   Correction.

 Technical Assistance Grants to Groups at NPL
 Sites;  Advance Notice  of  Rulemaking  and
 Request  for  Comments.

 Financial Assistance Program for Cooperative
 Agreements  under  the  Superfund Innovative
 Technology Evaluation  (SITE) Program.  Notice
 of Availability for Review.

 Interim   Guidance  on   De  Minimis   Waste
 Contributor Settlements. Request for Public
 Comment.

 Science Advisory Board, Hazard Ranking System
 Review Subcommittee; Open Meeting, July 16-
 17,  1987.

 Withdrawal  of  Arbitration  Procedures  and
 Natural  Resource  Claims  Procedures for the
 Hazardous  Substance  Superfund.    Proposed
 Rule.

 Science Advisory Board, Hazard Ranking System
 Review Subcommittee; Open Meeting, July 27-
 28,  1987.

 Draft Updated Health and Hazard Assessments
 for  Trichloroethylene and Dichloromethane.
 Notice of  Availability  of External  Review
 Drafts.
                                      387
-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1987
                       EPA FEDERAL REGISTER SUPERFUND
                           DOCUMENTS IN FISCAL 1987
                                   (continued)
Date

20.  July 22


21.  July 22


22.  July 27


23.  Aug. 4



24.  Aug. 4


25.  Aug. 5



26.  Aug. 27



27.  Sept. 2



28.  Sept. 3



29.  Sept. 8
Citation

52 FR 27620


52 FR 27643


52 FR 28038


52 FR 28867



52 FR 28866


52 FR 29060



52 FR 32496



52 FR 33284



52 FR 33446



52 FR 33812
30.  Sept. 22     52 FR 35577
Authority

NPL  for Uncontrolled Hazardous Waste Sites
Proposed  in Updates  #2-6.   Final Rule.

NPL  for Uncontrolled Hazardous Waste Sites;
Federal Facility  Sites.   Proposed Rule.

Interim Guidance  on Covenants  Not to Sue.
Request for Public  Comment.

Science Advisory Board, Hazard Ranking System
Review  Subcommittee; Open Meeting,  August
20-21, 1987.

Interim  Guidelines  for  Preparing  NBARs.
Extension of  Public  Comment  Period.

Science Advisory Board, Hazard Ranking System
Review Subcommittee; OpenMeeting, September
14-15, 1987.

Interim   Guidance   on   Compliance   with
Applicable  or  Relevant  and  Appropriate
Requirements.   Notice of Guidance.

Interim   Guidance  on  De   Minimis   Waste
Contributor Settlements.  Extension of Public
Comment Period.

NPL  for Uncontrolled Hazardous Waste Sites,
Notice of Intent  to  Delete Sites.  Request
for  Comments.

Withdrawal  of  Arbitration  Procedures  and
Natural   Resource  Claims  Procedures  for
Hazardous Substance Superfund  as proposed
on July 13, 1987.   Final Rule.

Notice of Proposed Settlement under CERCLA;
Union Chemical  Co.,  Inc.   Cost Recovery at
Hazardous Waste Site in South Hope,  Maine.
                                      388
-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1987


                        EPA FEDERAL REGISTER SUPERFUND
                            DOCUMENTS IN FISCAL 1987
                                    (continued)


Date               Citation             Authority

31.  Sept.  23      52 FR 35767       Notice of  Workgroups  Convened  to Develop
                                     State-recommended Guidance for State Capacity
                                     Assurance Requirements  under CERCLA.

32.  Sept.  29      52 FR 36461       Interim Guidance  on Covenants  Not to Sue.
                                     Extension of Public Comment Period.
                                       389
-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1987
                                  APPENDIX F

                         EPA INSPECTOR GENERAL REPORT
                            UNDER SECTION 301(h)(2)
                               TABLE OF CONTENTS

                                                                          Page

SCOPE AND OBJECTIVES	         426

SUMMARY OF RESULTS  	         427

DETAILS OF REVIEW 	         428

      Annual Report Chapter 2.0 -- Responding to Releases
      of Hazardous Substances  	         428

      Annual Report Chapter 7.0 -- Development and Evaluation
      of Permanent Treatment Technologies  	         434

      Annual Report Chapter 13.0 -- Executive Branch Estimate
      of Resources Needed to Complete CERCLA Implementation  	         434

      Annual Report Appendix C -- Detailed ROD Descriptions  	         435

      Annual Report Preparation Process  	         435

EXHIBITS

      EXHIBIT 1 -- FY87 Activities Annual Report vs.
                   Regional Records  	         437

      EXHIBIT 2 -- Review of Regional Records for FY87  	         439

      EXHIBIT 3 -- Feasibility Study Write-Up Example  	         440
                                      390
-------
      ; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON, D.C. 20460


                               APR   6  1989


MEMORANDUM
                                                           THE INSPECTOR GENERAL
SUBJECT:  Audit Report No. E1S4*7-11-0037-9100236
          Review of the Fiscal Year 1987
          Superfund Report £o Congress

FROM: ^yjohnC"~*Martin
        (  inspector General (A-109)

TO:       William K. Reilly
          Administrator (A-100)
SCOPE AND OBJECTIVES

     This  report presents  the results  of our  review  of  the  Environmental
Protection  Agency's  (EPA)   Annual  Report  to  Congress  on  Progress  Toward
Implementing Superfund:  Fiscal Year 1987  (Annual Report).  The  objectives  of
our  review were  to determine  whether the Annual  Report  is reasonable  and
accurate, as required by Section  301(h)(2)  of  the Comprehensive  Environmental
Response, Compensation, and Liability Act (CERCLA).

     We conducted our review between January 15, 1988, and January 23,  1989,  at
EPA Headquarters and in EPA Regions 2, 5, 8, and 9.  We  completed most of our
work by August 1988, when EPA  sent  the Report  to the Office of Management and
Budget (OMB) for review.  However,  we  also  reviewed  the  final changes made  to
the Report in January 1989,  after OMB's review had been completed.

     Our work focused on Fiscal Year 1987 (FY87) activities.  Numerous  auditors
familiar  with  the  Superfund  program  reviewed the  entire  Annual Report  to
determine if there were any sections which did not appear to be reasonable and
accurate.  We performed detailed audit work in EPA Headquarters and Regions  2,
5, 8, and 9  to verify the accuracy of key  information presented in Chapters 2.0,
"Responding to  Releases of Hazardous  Substances",  and 7.0,   "Development  and
Evaluation of Permanent Treatment Technologies".  These chapters  of the Annual
Report addressed five  of  the  seven  areas specifically  required by  Section
301(h)(l) of CERCLA.  We did not  perform detailed audit  work  on  Chapter 13.0,
"Executive   Branch  Estimate   of  Resources   Needed   to   Complete   CERCLA
Implementation", another area which CERCLA required,  since the Agency  provided
only current  budget figures  in  response  to  this  requirement.    Finally,  we
reviewed Appendix C, "Detailed ROD Descriptions", to determine  if the summaries
presented were reasonable.

     Throughout  the course  of  our  review,  we brought  the  concerns  which  we
identified  to  the  Agency's  attention.   The  Agency corrected  most  of  these
concerns.

     Except  as  noted below,  our work was  performed  in accordance with  the
Standards  for  Audit  of Government Organizations,   Programs,  Activities  and


                                     391
-------
                 Progress Toward Implementing Superfund: Fiscal Year 1987


Functions (1981 revision) issued by the Comptroller General of the United States.
We did not perform a full scope audit to determine if the Superfund program is
achieving the results required by  CERCIA, nor did we perform extensive tests to
determine if internal controls are adequate.  We performed audit work we believed
necessary  to  determine if  key information included  in the  Annual  Report is
reasonable and  accurate.  Furthermore, for  the  items  not tested,  based on our
review, nothing came to our attention which warranted more detailed audit work
than that described  in the DETAILS OF REVIEW section.

SUMMARY OF RESULTS

     We found that some of the areas presented in the Annual Report, such as the
information presented  in Chapter  7.0  on the Superfund Innovative Technology
Evaluation  (SITE)  Program,  were generally reasonable and accurate.   However,
other important areas of the Report included information which was not reasonable
and accurate, and  some  information was not  as complete  as  it could have been.
In addition, the process the  Agency  used to prepare  the Annual Report was not
completely effective.

     Certain information presented in Chapter 2.0 of the Annual Report was not
reasonable or accurate.  First,  program accomplishments  figures were frequently
inaccurate because the Agency used Headquarters information systems which were
not reliable to prepare  its Report.   Many  of their figures  did not agree with
the corresponding  information secured from Regional  systems, and significant
portions of the Regional claims were not supported by valid  source documents.
In addition, Appendix D of the Annual Report, which shows the  status of Remedial
Investigations/Feasibility Studies (RI/FS) and Remedial Actions (RA) on September
30, 1987, identifies delays which occurred since January 1,  1987,  but does not
identify any delays which may have occurred prior to that date.

     The Agency's official definitions of two terms used in the Annual Report,
the "start" of key program activities and "operable unit", may lead the reader
to believe that more on-site work was done, at a greater number of facilities,
than actually occurred.  Specifically the Agency defines "start" as a financial
transaction, i.e., when  funds  are  obligated to begin  work.   No actual on-site
cleanup work needs to be performed to qualify as a  "start", and many months can
elapse between  the obligation of funds and  the commencement  of  on-site work.
In addition, EPA frequently divides  Superfund "sites" into "operable units" to
more easily manage the cleanup process.   One site can  have ten or more operable
units,  creating difficulty  in correlating  the number  of cleanup  actions taken
during FY87 with overall cleanup progress at Superfund  sites.

     In two areas of the Annual Report, we believe  the  information presented was
not as complete as it could have been.  First, CERCLA  requires  the  Agency to
provide an  estimate  of the  resources needed to  complete implementation of the
statute.  In response,  however,  EPA provided only the Agency's FY87  through FY89
budget figures.  Second, we do not believe  that the level of detail provided in
the feasibility studies descriptions  is sufficient, so that the reader can fully
understand and  appreciate EPA's decision-making process.

     Finally,  the process  used to  prepare  the Annual Report was  not fully
effective.  For example,  the  Report  coordinator's  resources were limited, and
                                      392
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


key end of fiscal year data was still uncertain and,  in some cases,  unavailable
for  our  review  until  April  1988.   As  a result,  the Annual  Report was  not
completed until January 1989,  even though  it was  due  to Congress  on January 1,
1988.

     The  details of  our  scope,  methodology,  and  results  of  review for  the
concerns summarized above are presented in the DETAILS OF REVIEW section of our
report.


DETAILS OF REVIEW

                       Annual Report Chapter 2.0 - Responding to
                           Releases of Hazardous Substances

     As previously stated, some of the information in the  Annual Report was not
finalized until  January 1989.   In order that our  review would not  delay the
Report any further, we began  our  field work by using  a January  1988 draft,  and
used updated drafts  as  they  became  available.    We  identified  the types  of
information  included in the Report, and  specifically  focused our  field work on
those items CERCLA required.  We then selected four Regions  in which to perform
our  detailed audit work:    Regions  2 and  5  because  of their  heavy volume  of
Superfund activity;  and Regions 8 and  9  because  of their  significantly  lower
volume.  Recognizing Regional  differences, we hoped  in this manner  to obtain a
balanced, nationwide perspective  in our  review.

     We  initially  planned  to select a  sample of  cases  for review from  the
Headquarters information  systems  being  used  to prepare the Annual  Report.   In
early December 1987,  we began requesting  details on which systems were  being
used.  As of January 15, 1988, when we began our review, the Report  coordinator
could not  tell us  all  of  the systems  that would be used to  provide  input.
Therefore, because we did  not  have a universe of cases from Headquarters records
from which to  select  a  sample, we obtained FY87  information directly  from the
EPA Regions.   Regional  officials provided this information from a variety  of
computerized and handwritten  systems, and  stated  that it  was the  most accurate
available.

     We  first  verified the accuracy  of the Regional numbers  by interviewing
Regional staffs and reviewing source  documentation.  In some cases,  we reviewed
100 percent of the actions; however,  if  the number was prohibitively large,  we
randomly selected  a  sample for review.   We also  selectively reviewed a  small
number of end  of year actions to determine whether there existed instances  in
which Superfund accomplishments were  merely "paper transactions" and no on-site
work was  actually performed.  We did not perform a statistical sample; therefore,
the results of our review should not be projected throughout EPA.

     Although the Annual  Report  shows  totals  by Region for Removal Starts and
Removal  Completions,  it  shows  only nationwide  totals  for  the  other  major
Superfund activities  we  reviewed.   The  Report   coordinator provided us  with
Regional information on these  other activities late  in our  review.   Therefore,
at the conclusion  of our field  work,  we compared  the totals  provided by the
Regions to those  provided  by the coordinator.  We could not make  this comparison
                                      393
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


earlier because,  in most cases, the Report coordinator was unable to provide the
Regional details until April 6, 1988.

     Although we cannot state conclusively what the correct figures  are,  it is
evident from  our work that some  of  the information  presented in this Report
chapter  is not  completely  reliable.    In  virtually every  case,  the  total
accomplishments figures included in the Annual Report did not agree with Regional
records (see Exhibit 1 at the end of  this report).  And,  as Exhibit 2 shows,  30
percent of removal activities and 13 percent of remedial activities  claimed by
the Regions were not supported by valid documentation  in the Regions' files.
Specifically,  in many cases the Regional officials could  not provide  any source
document clearly  showing  that the accomplishment claimed actually occurred in
FY87 ("source  document not located").  In a number of other cases,  the documents
provided by Regional officials showed that,  according to Agency definitions, the
accomplishment should have been  claimed in another fiscal year ("invalid FY87
actions").

Removal Starts and Completions

     The Annual Report showed a total of 97 Removal Starts  for Regions 2,  5,  8,
and 9, while  these Regions reported 107 Removal  Starts  to the auditors.    The
total of 75 Removal Completions  in the Annual Report was  less than  the  total
reported by the Regions.  We sampled 32  starts and 18 completions and found  that,
according  to Agency definitions,  28  starts and seven completions  (70 percent)
were supported as valid FY87 actions.   (Figures 1 and 2 below.)

                                   FIGURE 1
                               REMOVAL STARTS

           Starts Per:
          Annual          Sample  Valid FY87  Source  Documents  Invalid FY87
  Region  Report  Region   Size    Actions      Not Located     	Actions

    2       36      40      4         4
    5       35      40      7         7
    8       11      11      6         6
    9       15     _16     15        11               4
  Total     97      107     32        28               4                0
                                      394
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                 Progress Toward Implementing Superfund: Fiscal Year 1987
 Region

    2
    5
    8
    9
 Total
Completions Per:
Annual
Report    Region
  29
  30
   4
  12
  75
33
37
 4
12
86
                                    FIGURE 2
                             REMOVAL COMPLETIONS
Sample
 Size

   4
   O1
   2
  12
  18
               Valid FY87
                Actions
2
1
7
        Source Documents
          Not Located
IQ
10
           Invalid FY87
             Actions
1
1
 1 Review of a sample was not performed due  to  time  constraints.   We were
 forced to curtail our review  to  keep  pace with the  Agency's early schedule
 for Annual Report issuance.
Preliminary Assessments and Site Inspections

     The Annual Report included 1,925 Preliminary Assessments (PA) as completed
in FY87.   The  four Regions  which we  reviewed reported  that  1,958  PAs  were
completed.  In addition, the  Annual Report indicated that 514 Site Inspections
(SI)  were  completed in FY87,  while these  Regions  reported 518.   Of  the 36 PA
completions and 40  SI completions  we  examined,  26  PA and 33 SI  completions (78
percent) were valid FY87  actions.   Figures 3 and  4  below provide the detailed
results of our review.
                                    FIGURE 3
                     PRELIMINARY ASSESSMENT COMPLETIONS
 Region

    2
    5
    8
    9
 Total
Completions Per:
Annual             Sample  Valid FY87
Report    Region    Size    Actions
            524      12         11
            814      12          7
            134       2          1
            486      10         _7
          1,958      36         26
                           Source Documents
                             Not Located
                                      Invalid FY87
                                        Actions

                                           1
                                           4
                                           1
                                           3
                                           9
                                      395
-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1987
 Region

    2
    5
    8
    9
 Total
                                    FIGURE 4
                          SITE INSPECTION COMPLETIONS
Completions Per:
Annual             Sample  Valid FY87
Report    Region    Size     Actions
  152
  224
   34
  104
  514
 152
 228
  34
 104
 518
 10
 22
  1
 _7
 40
                            Source Documents
                              Not Located
  10
  16

  _7
  33
                                      Invalid FY87
                                        Actions
Remedial Investigations/Feasibility Studies

     The  Annual  Report  included 100 RI/FSs  in FY87  for the  four Regions  we
reviewed.  However, these Regions reported only 96 RI/FS starts to the auditors.
We sampled 62 RI/FSs and found 55 (89 percent)  were valid FY87 actions.  (Figure
5 below.)
                                    FIGURE 5
                  REMEDIAL INVESTIGATIONS/FEASIBILITY STUDIES
  Region
  Starts Per:
 Annual
 Report  Region
      Sample  Valid FY87
       Size    Actions
                   Source  Documents
                    Not Located
                            Invalid FY87
                              Actions
    2
    5
    8
    9
  Total
   30
   45
   10
   15
  100
30
42
10
14
96
 5
42
10
_5
62
 5
41
 4
_5
55
Records of Decision/Selection of Remedy

     We  found that the  number of Records  of Decision  (ROD)  which the  Annual
Report indicated were signed in FY87 was almost identical to the figure presented
by the Regions.  The Agency reported 40 completed RODs  for the Regions which we
reviewed, while  these Regions reported 39.   We  reviewed the  39 RODs  and found
that only one was  not a  valid FY87  action.

Remedial Designs and Remedial Actions

     Our scope of review for these two actions included Regions 2,  5, and 8 (due
to time constraints,  we  could not complete  field work in Region 9).   The  Annual
Report included  47  Remedial  Design  (RD)  starts,  compared  to 39  reported  to the
auditors by the three Regions.  The Annual Report stated that 26 RAs were started
in FY87, while  the three Regions reported  21 RA starts.  Twenty-one  of  the 24
                                      396
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
RD starts and all of the 15 RA starts  that we  reviewed were  supported by source
documentation as FY87 actions.  (Figures  6 and 7 below.)

                                   FIGURE 6
                            REMEDIAL  DESIGN STARTS
  Region

    2
    5
    8
  Total
 Starts Per:
Annual
Report
  22
  18
  J_
  47
Region

  19
  13
  _7
  39
Sample
 Size

   3
  141
  _7
  24
Valid FY87
 Actions

    3
   13
   _5
   21
Source Documents
  Not Located	
Invalid FY87
  Actions
                       1
                       2
                       3
  1 The sample is greater than the Regional figure because we located an
  additional FY87 start in the Region's files.
                                   FIGURE 7
                            REMEDIAL ACTION STARTS
  Region

    2
    5
    8
  Total
 Starts Per:
Annual
Report
  10
  12
  _4
  26
Region
  10
  _3
  21
Sample  Valid FY87
 Size    Actions
   2
  10
  _3
  15
            Source Documents
              Nojt Located
                  Invalid FY87
                    Actions
    2
   10
   _3
   15
Additional Comments

     During our review,  we  also identified concerns with the Annual Report  in
such areas  as definitions  of  terms  and RI/FS  timeframes.   Further, a  recent
Office  of  Inspector  General (OIG) "Capping" Report  titled  EPA,  Office  of the
Inspector General Audits of Superfund Cooperative Agreements for Fiscal Years
1985 through 1987 (Audit Report No.  E5eE8-09-0018-80838),  dated March 29, 1988,
consolidated the results of  numerous OIG reviews and pointed out many of the same
concerns that we are reporting.

     The Annual Report  includes  information on the number of "starts" for various
activities.   During  our review we found  that  there  is confusion among  Agency
personnel on  how a  "start"  is  defined.   The Agency officially defines "start"
as  a  financial  transaction,  i.e.,  when  funds  are  obligated to  perform the
activity.   It  is   important for  the  reader  to  understand that  under this
definition, no actual on-site work needs to have begun to  officially qualify  as
a start.   Our review of Regional records  showed that for many "starts", only
funding transactions occurred during  FY87.  So  although these met the Agency's
definition, no  actual  on-site  work took place.   For  example,  three of  the  42
                                      397
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


RI/FS starts  and three of the ten RA starts which  Region 5 reported were for
funding documents prepared in September 1987, but no on-site work had begun at
the time of our  review  in February 1988.  The OIG "Capping"  Report discussed the
same  condition.   Further,  while  this  definition may  be  widely known  at
Headquarters, many Regional officials were not aware  of  it.  This  caused problems
in our review, because  when questioned, Regional officials frequently had to ask
the auditors  to define a "start" before they could  give us any  information.

     We believe  that  it is  important  for the  reader  to  fully  understand the
Annual  Report's discussion  of "operable  units",  and the  implications this
recordkeeping method has for  overall  Superfund  accomplishments.  EPA frequently
divides Superfund "sites" into "operable units"  to more easily manage the cleanup
process.  Each of these operable units  (OU)  may address a different problem at,
or a different portion of, a site.  For example, one site  in Region 8 had four
operable units.   An RI/FS was completed on one OU during FY87,  and RI/FSs were
in  process on  the  other  three OUs.   These  three OUs  will be  reported  as
completions in future years,  but they all  pertain to that  one  site.  At another
Region 8 site, records  showed that as many as 11 OUs  existed.   Five  of the seven
Region 8 RODs signed during FY87 were for OUs at this one site. Because EPA uses
this method of recordkeeping,  it is difficult to correlate the number of actions
(RI/FSs, RODs, etc.) taken during FY87 with overall cleanup progress  at Superfund
sites.

     Appendix D of the Annual Report shows the status  of active RI/FSs and RAs
on September 30,  1987.  This table  shows the planned completion date  as estimated
on January 1, 1987.  However,  the  table may not show any previously published
schedules for RI/FSs and RAs.   Therefore, if  a project will not meet  a previously
published  schedule, the  table will  not reveal this  fact.   Section 2.4 of the
Annual Report states that EPA chose  the  January 1, 1987, date because it marked
the first  update for RI/FS and RA projects  after the hiatus between Superfund
authorizations.   Further, EPA officials believed that  choosing  an earlier date
would have  included  time lost due  to circumstances beyond  EPA's  control.
However, regardless of  what may have caused the delays,  EPA is not providing the
precise information required by CERCLA Section 301(h)(1)(C).

     The "Capping" Report identified the same concerns  we  did with  the accuracy
of  the  Agency's  Superfund  information  systems.    For  example,   the  CERCLA
Information System (CERCLIS)  is one of EPA's key tracking  systems and represents
an inventory  of  all potential  hazardous waste  sites known to EPA.   OIG audits
have found that  Regions  are  not inputting accurate  and up-to-date information
into CERCLIS.  Even though the Agency was  aware of these problems,  It relied on
CERCLIS for some information in the Annual Report.

     Finally, the  "Capping"  Report summarized problems  with documentation in
Regional files,  which we also found during our  review.  In  many  cases, Regional
officials had great difficulty  locating the required source documents in their
files,  and in some cases  they could  not find these  documents at  all.   For
example, Exhibit  2  shows that source  documents  could not be  located  for  28
percent of the  removal actions and  three percent  of  the  remedial actions  we
reviewed.
                                      398
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                 Progress Toward Implementing Super-fund: Fiscal Year 1987


     In  discussing  the  discrepancies between the numbers  in the Annual Report
and those that Regional officials provided to the auditors, Office of Emergency
and  Remedial  Response  (OERR)  officials  stated  that  they  considered  the
differences to be minor.  These  officials  objected  to our securing information
from the Regions, stating that Headquarters management systems are the official
Agency  systems  to  which  the Regions  report.    Further,  the Director  of OERR
explained that  there  is only one EPA "system",  and that  even though some data
in this  system was  not  accurate,  the problem  is data  entry into the system.

                      Annual Report Chapter 7.0 -- Development and
                     Evaluation of Permanent Treatment Technologies

     We  reviewed the   information  presented  in the  Agency's  report  on  the
Superfund Innovative Technology Evaluation  (SITE) Program, since most of the FY87
progress made in developing and evaluating permanent treatment technologies was
centered in this program.  We again used the January 1988 Report draft to begin
our  field  work,  and  reviewed  updated drafts  as  they became  available.   To
determine if  the  information presented on the  SITE Program  was reasonable and
accurate, we interviewed officials from the Office of Solid Waste and Emergency
Response (OSWER) and the Office  of Research and Development  (ORD),  who jointly
administer the program.   Additionally, we visited ORD personnel at the Hazardous
Waste Engineering Research Laboratory, who are responsible  for  the technical
aspects  of  the  field demonstrations,  and  reviewed  available files  and source
documentation.  Based on our review,  we believe that  the  information presented
on the SITE Program is  generally reasonable and accurate.


                     Annual Report Chapter 13.0 -- Executive Branch
              Estimate of Resources Needed to Complete CERCLA Implementation

     We did not  perform  in-depth  audit work on this chapter of the Annual Report,
because  it consists of  FY87  obligations,  the resource estimates  from the FY88
Operating Plan,  and  the  Agency's  budget request for FY89, all  of which is readily
available information.  We wish  to emphasize that the figures presented are not
estimates of the exact Agency needs for completely accomplishing the requirements
of CERCLA.

     The language of CERCLA suggests that Congress may have wanted estimates in
the Annual Report  for the total cost of completely  implementing  the statute.
Although some projections beyond FY89 were included in one  of  the  last drafts
of the Annual Report, they were  removed during  the Agency review process.

     During the Agency's  internal review of the Report,  the Office  of General
Counsel commented that  the resource  projections in Chapter 13 do not go as far
as the statute requests. Further, the Office of Policy,  Planning and Evaluation
recommended a more  comprehensive approach  for  future  reports.

     We are not aware of any current,  comprehensive study within EPA to define
the needs for accomplishing the  CERCLA requirements.  However,  a recent report
by the Surveys and Investigations Staff of the Committee on Appropriations, U.S.
House of Representatives, points out the gap between  current Superfund funding
and potential "real" needs.   In a March 1988 report,  Status of the Environmental
Protection Agency's Superfund  Program,  the committee staff  stated  that, using

                                      399
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


average cost estimates  to  clean up National Priorities List  (NPL)  sites,  "793
sites (would) require Federal funds ranging from  about $16.7  to  $23.-8 billion,
far in excess of the available $8.5 billion."  The report  also noted that  this
estimate does not  account  for the possibility of hundreds of new  sites being
added to the NPL.

                  Annual Report Appendix C -- Detailed ROD Descriptions

     Historically, Congress  has  expressed concerns with some aspects of EPA's
decision-making processes.   One purpose of the CERCLA requirement  for detailed
feasibility studies descriptions was to help Congress better understand  how EPA
makes decisions on Superfund sites.

     The DIG believes that the level of detail contained in the Annual Report's
feasibility studies descriptions does not provide sufficient information so  that
EPA's decision-making process on Superfund sites  can be fully understood.   The
feasibility studies  write-ups generally contained a brief description of  the
site, discussion of  initial  work done  at  the site, overview  information about
the feasibility studies  (including only one sentence summaries of  the  cleanup
alternatives considered),  selected information on the requirements  considered,
and a brief summary of the reasons for selecting  the chosen remedy.

     In our opinion,  the descriptions of the  cleanup  alternatives need to be
expanded to  clearly  demonstrate the extent  of EPA's decision-making efforts.
The ROD documents, from  which the  Annual  Report was prepared, contain  a great
deal of  information on  the  alternatives, such as  costs,  benefits (including
consideration  of  CERCLA  goals),  and  risks  to   the  public  health and   the
environment.    If  the  feasibility  studies  descriptions  had  contained  this
additional information, it would have greatly aided the  reader in understanding
how EPA made these decisions.

     Exhibit 3 to our report is an example of a more  complete  feasibility study
write-up, which we believe demonstrates the additional information  that should
have been made available to  the reader.

                          Annual Report Preparation Process

     The process  used to  prepare  the  Annual Report was  not  fully effective.
Although this Report  was due to Congress January 1,  1988, the Report  was  not
completed until  January 1989.   Since this  is  the first  time  the Report  was
prepared, some problems were  expected.  However, the problems which we identified
in our report seem to have been much greater than they should have  been.

     Part of the reason that the Annual Report encountered such difficulties is
that the Report coordinator's resources were limited.  Also, at his  grade level
(GS-13), he was not in a position  of authority from which  to  command action on
the part of other organizations whose  input was vital.  For example,  as of March
1988, the Report coordinator was still uncertain of the sources and accuracy of
many of the  accomplishments figures in the  Report.  Despite our repeated requests
for detailed information over a period of four months, he  was unable to secure
the information from the Agency offices responsible for compiling it.  Further,
the coordinator had  different figures for the same accomplishments, depending
on which information system he used.  This  should not be the case six months

                                      400
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                 Progress Toward Implementing Superfund: Fiscal Year 1987


after the  end  of the fiscal year,  and is a further  adverse  reflection on the
reliability of the Agency's  information systems.

     OSWER officials stated that the main information system,  CERCLIS, has been
improved for FY88.  These officials believe  that the use  of the improved CERCLIS
will enhance the accuracy of the  FY88 Annual Report, as  well as decrease its
preparation time.   However,  this system will  also  contain information that is
not reliable, unless  steps are taken  to ensure  that  Regional input to CERCLIS
is accurate and  complete.
                                      401
-------
                    Progress Toward Implementing Superfund:  Fiscal Year 1987
oo
>
u.
z
ui
     2000
     1800
     1600
     1400
1200
     1000
      800
      600
      400
      200
                                       Exhibit 1
                                   FY87 Activities
                        Annual Report vs. Regional Records
                                         1925
                          ANNUAL REPORT
                          REGIONAL RECORDS
                  97
                        107
                                  75   86
                                                            1958
                   Removal
                    Starts
                             Removal
                            Completions
 Preliminary
Assessments
                                                                514  518
   Site
Inspections
                                        ACTIVITIES
                                        402
-------
N.
00
1L
z
UJ
3
O
     120
     110
     100
      90
      60
70
60
      60
      40
      30
      20
      10
                   Progress Toward Implementing Superfund:  Fiscal Year 1987
                                       Exhibit 1
                                      (continued)

                                 FY87 Activities
                       Annual Report vs. Regional Records
                 100
                       96
                                                         ANNUAL REPORT
                                                         REGIONAL RECORDS
                                          47
                                 40   39
                                                      39
                                                                26
                                                                      21
             Remedial Investigations/
               Feasibility Studies
                            Records of
                            Decision
Remedial Design
   Starts
Remedial Action
   Starts
                                       ACTIVITIES
                                        403
-------
     Progress Toward Implementing Superfund:  Fiscal Year 1987
                       Exhibit 2




                Review of Regional



                 Records for FY87
                 28%
                                                        10%
Removal Program
Remedial Program
                     Valid FY87 Actions
                     Invalid FY87 Actions
                     Source Documents Not Located
                        404
-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1987


                                   EXHIBIT 3

                      FEASIBILITY STUDY WRITE-UP EXAMPLE


     This exhibit highlights the additional information we believe  should have
been included  in the feasibility  studies  write-ups.   As  an example, we have
inserted this extra information, quoted from the ROD,  into the existing Annual
Report text  on  the  Laskin/Poplar Oil  Site.  We have indented this  additional
information to identify it for the reader.


                            LASKIN/POPLAR OIL SITE
                        SOURCE MATERIAL OPERABLE UNIT
                            ASHTABULA COUNTY, OHIO

HRS Score:  35.95                                                     NPL Rank:  492

Background

     The Laskin/Poplar Oil Site  is located west of the village of Jefferson  in
Ashtabula County, Ohio.   The  9-acre  site  is  bounded by Cemetery Creek and the
Ashtabula Fairgrounds.   The site was  formerly  used  for greenhouse  operations
beginning in the 1930s.   Boilers were  installed to heat the  greenhouses in the
1950s,  and tanks to hold  waste oil for burning were  built in the 1960s.  When
the  greenhouse  business  declined,  the owner   of  the site  began  collecting,
reselling, and disposing  of waste oils, much of which  contained PCBs  and other
hazardous materials.

     The State of Ohio initiated action against the site owner in 1979 for air
and  water  pollution violations.   In  late 1980,  EPA evaluated  the need for
remedial action  at  the  site and in 1982 undertook an emergency action, which
included  removing  302,000  gallons   of  oil,  treating  430,000   gallons   of
contaminated water,  and  solidifying  205,000  gallons  of  sludge.    Potentially
responsible parties (PRPs) removed another 250,000 gallons  of oil wastewater  in
1985 and 1986.   EPA  issued an Administrative Order of Consent to 12 PRPs between
1984 and 1986,  requiring  their participation in the remediation process.

     EPA divided remedial activities at the site into  two operable units and  an
overall site investigation.   The  first operable  unit addressed the incineration
of contaminated water and  PCB-contaminated oils.  The ROD for the second operable
unit,  which  focused  on  source  material  that  remained  on   site,  was  signed
September 30, 1987.  The overall  site investigation still is being  conducted and
will address ground water, surface water,  and soil contamination as  well as the
extent of dioxin contamination.

Description of Site Work

     When the overall RI was initiated,  the site contained 34 tanks,  4 pits, and
treatment and retention ponds.   Preliminary sampling  indicated large amounts  of
seepage from tanks and unlined pits into surrounding soils.  Investigations also
identified a threat from  contaminants leaching  into  ground and surface water,
                                      405
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


including Cemetery Creek, which runs into the Grand River,  a source of drinking
water for 25,000 residents.

     Potentially responsible parties, under  consent order,  initiated  the  study
for  the  second operable  unit in 1985  to characterize  the remaining  on-site
wastes.  Results indicated that waste materials still  present at the site  after
emergency  removal  actions  posed a  serious  threat  to  human health  and  the
environment through the threat of fire and exposure to PCBs.   Major contaminants
of concern at the site are PCBs, polynuclear aromatic hydrocarbons  (PAHs),  and
volatile  organic  compounds   (VOCs),  all   of  which  were  present   in  high
concentrations in waste oil and surrounding  soils.

Description of Feasibility Study

     The Phased Feasibility Study (PFS) for  the second operable  unit  evaluated
remedial alternatives  for  the  removal of source materials,  including  sludges,
waste oils, wastewaters, and contaminated soils (included in this operable unit
because they  were  a source  of potential contamination  of  ground and  surface
water).  All attempts were made during the PFS to ensure that the  alternatives
developed for this operable unit were consistent with  final  remediation for  the
site.  Remedial alternatives developed included the following:

                                 Alternative 1

          Under this alternative, no remedial action would be  taken
          at  the  site.    The  threat  to   public  health   and  the
          environment would remain.

                                 Alternative 2

          Alternative  2  consists of solidifying  all  of the liquid
          wastes and placing all of  the source  material in a  licensed
          TSCA or RCRA facility  as  appropriate.   All tanks would be
          dismantled and taken  off site.   The  pit  area  would be
          backfilled  with  on-site   soils  and graded  to   preclude
          ponding.

          No long-term maintenance or monitoring at the Laskin/Poplar
          Oil site would be required under this alternative.   However,
          the waste would not be treated prior to landfilling at the
          licensed  facility.    The   long-term dependability  of  any
          landfill is  unknown.   The  cost estimate for Alternative  2
          is $4.2 million.

                                 Alternative 3

          Alternative  3  combines on-site incineration of the  oils,
          sludges, and source soils with off-site  treatment of  the
          wastewaters,  decontamination water, and scrubber water.  The
          incinerator  ash  and  dismantled tanks would be  disposed  in
          an off-site RCRA licensed facility.  If tests indicated that
          the  ash  could  be  delisted,  the  ash could be sent  to  a
                                     406
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       Progress Toward Implementing Superfund:  Fiscal Year 1987
sanitary  landfill.    The  excavated  pit   area  would  be
backfilled with onsite  soils and graded to preclude ponding.

This option would not require any long-term maintenance or
monitoring  at  the  site.    All  source material would  be
treated  to the greatest  extent practicable.   The  cost
estimate for Alternative 3 is $8.5 million.

                       Alternative  4

Alternative 4 utilizes off-site incineration for all oils,
sludges, and highly contaminated soils.  All wastewaters and
decontamination  water would  be  treated  at  an  off-site
treatment  facility.    The  tanks would be  demolished  and
disposed of at  a licensed facility offsite.  The excavated
areas would be backfilled with on-site soils and graded to
preclude ponding.

This option would not require any long-term maintenance or
monitoring  at  the  site.    All  source material would  be
treated  to the greatest  extent practicable.   The  cost
estimate for Alternative 4 is $12.2 million.

                       Alternative  5

Alternative 5 includes on-site incineration of  all oils and
sludges as  well as soils  with greater than 25  parts  per
million (ppm) PCBs or  500  ppm total  halogenated organics.
The remainder of soil  excavated from  the tank and pit areas
would be landfilled off  site  at  a  RCRA licensed hazardous
waste  facility  along  with  all  dismantled tanks.    All
wastewaters, decontamination water, and scrubber water would
be treated at  an off-site treatment  facility.  The excavated
areas would be backfilled with on-site soils and graded to
preclude ponding.

This alternative would not require any long-term maintenance
or monitoring  at  the  site.   The most highly  contaminated
source material would  be  permanently  treated.   However,  the
soils that would be landfilled, which comprise  roughly one-
half of the source material, would not be treated.  The off-
site  disposal  of  waste without treatment  is the  least
favored option  under  SARA.   The cost  of Alternative  5  is
$5.8 million.

With the exception of  no  action (Alternative 1), all of the
alternatives would effectively and permanently  minimize the
danger to the public health and the environment at the site
area through the removal of the contaminated material.

The use of  an off-site landfill  (Alternatives  2  and 5)  is
conventional,  easy to implement, and transfers the operation
                           407
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       Progress Toward Implementing Superfund:  Fiscal Year 1987
and maintenance to the owner/operator of the landfill.  The
most significant disadvantage of this option is that it does
not  treat  the  contaminants  so there  is no  reduction in
toxicity, volume, or mobility.  It also  may be  difficult to
maintain  the   long-term   integrity  of  hazardous  waste
landfills as  required by the  U.S.  EPA's off-site policy.
The  off-site  disposal  of contaminated  materials without
treatment is the least preferred  option under  SARA.

The   off-site   incineration   of   the   source  materials
(Alternative  4)   offers   the  advantage  of  permanently
destroying the  contaminants  in the waste material and the
soils.  It is a proven technology that transfers operation
and  maintenance to the owner/operator  of the incinerator
facility. One of the most significant disadvantages of this
alternative  is  implementability.    The  material  must  be
packaged in small fiber drums  for transportation.

The  facilities  available have  commitments to their regular
clients  which  control when  and  at what  rates the source
material can be taken care of.   In  addition,  a number of
off-site  hazardous   waste   incinerators  have   shown  a
reluctance to accept the waste material due to high levels
of lead found in some of the sludges.   Transportation of the
waste  to an  off-site facility increases  both  the cost of
this  alternative  and  the risks  posed  to  the  public  by
movement of contaminated materials on the highways.

As   with  off-site   incineration,   on-site    incineration
(Alternatives 3 and 5) would utilize  a proven technology to
permanently destroy the contaminants in the source material.
The  advantages  of  this alternative are that the packaging
requirements necessary for  off-site incineration would be
avoided, and all material could be processed  in one year or
less   once   the  incinerator  begins   operation.     This
alternative also meets the  goal  of SARA of implementing a
remedial action which incorporates  treatment  rather than
land disposal where practicable.

A   comparison   of  the  alternatives   on  the  basis  of
protectiveness  of  public  health and the environment shows
that on-site and off-site incineration provide  a  high level
of  protection.   Alternatives  which  use  a high  degree of
landfilling provide  an equal  level  of  protection in the
short  run.    The  long  run  dependability   of  landfills,
however, is unknown.   There would be no beneficial  impacts
associated with the no action alternative.

Any  detrimental environmental effects associated with the
waste  and soil  removal operations would  essentially be the
same for each alternative except the no  action  alternative.
                            408
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


          These short term negative Impacts could be minimized using
          proper construction methods.

     The  PFS identified  the  Federal and  State applicable  or  relevant and
appropriate requirements (ARARs) that the  remedial action must meet, consistent
with the requirements of CERCLA.  One technology considered for use on the  site
was on-site containment of the wastes.  However,  because the RCRA land disposal
restrictions were  considered ARARs,  this option was  not considered  further.
Other  ARARs  identified  for  this  site  included  RCRA  thermal  destruction,
incinerator, and off-site transportation regulations;  Ohio Clean  Air Act  limits
on incinerator emissions; and Ohio regulations for the  off-site  transportation
of hazardous waste.

          The State of Ohio and the U.S. EPA expressed  preference for
          remedial actions that  would provide destruction of hazardous
          constituents in lieu  of transporting untreated  wastes  to a
          RCRA approved location.   Section 121(b)(l)  of  SARA states
          "Remedial actions in  which  treatment which permanently and
          significantly reduces  the  volume,  toxicity  or mobility  of
          the hazardous substances,  pollutants,  and contaminants  is
          a  principal  element,  are  to be preferred  over remedial
          actions  not  involving  such   treatment.      The  off-site
          transport   and   disposal   of  hazardous   substances    or
          contaminated materials without such  treatment should be the
          least favored alternative remedial action where  practicable
          treatment technologies are  available."

     Public  comment  on the  RI/FS was  received during  a public  availability
session, a public meeting,  and  through written comments.  Residents and local
officials supported the selected remedy discussed below.

Description of Selected Remedy

     The remedy  selected  was on-site incineration  of  all  oils,  sludges, and
contaminated  soils   and   the  off-site   treatment   of  contaminated  waters
(Alternative  3).     This  alternative   uses  a   proven  technology   (i.e.,
incineration), and, because contaminated  materials are  destroyed,  it  satisfies
CERCLA1s preference for permanent solutions and use of  treatment technologies.
The  remedy  also does  not  involve the off-site transportation of hazardous
materials (i.e., the oils,  sludges,  and contaminated  soils) before treatment;
when implemented,  it  will  provide  a high level of protection of human health and
the  environment.   The  remedy  is  also expected  to meet all ARARs  for  this
operable unit.   The  State  of  Ohio was consulted during the  remedy selection
process and concurred with the  chosen alternative.
                                      409
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987


                                  APPENDIX G

                                LIST OF EXHIBITS


Exhibit
Number                            Title of Exhibit                               Page

1.0-1         Summary of Fiscal 1987 Superfund Program Activities            3

1.0-2         Summary of Program Activity  by Fiscal Year                      4

2.2-1         Fiscal 1987 Removals by State                                  20

2.2-2         Removal Actions by Fiscal Year                                 24

2.2-3         Completed Removals by Incident Category                        25

2.3-1         Historical Superfund Pre-Remedial Program                      27
              Accomplishments

2.3-2         Map of National Priorities List Sites                          31

2.3-3         National Priorities List  Sites Per State/Territory            32
              July 1987

2.3-4         Historical National Priorities List Sites                      34

2.3-5         Fiscal 1987 Accomplishments  for Remedial Investigation/
              Feasibility Study Starts  and Records of  Decision               37

2.3-6         Historical Superfund Remedial Investigation/Feasibility       38
              Study Starts and Records  of  Decision

2.3-7         Summary of Remedy Selection  in Records of Decision            41
              Signed During Fiscal 1987

2.3-8         Historical Data on Remedies  Selected in  Records of
              Decision                                                       43

2.3-9         Fiscal 1987 Accomplishments  for Remedial Design and           44
              Remedial Action Starts

2.3-10        Historical Superfund Program Remedial Design  and               45
              Remedial Action Starts

2.4-1         Status of Remedial Investigation/Feasibility  Study
              and Remedial Action Projects at the End  of  Fiscal             54
              1987
                                      410
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                 Progress Toward Implementing Superfund: Fiscal Year 1987


                                LIST OF EXHIBITS
                                    (continued)


Exhibit
Number                            Title of Exhibit                              Page

2.4-2         Remedial  Investigation/Feasibility Study and Remedial
              Action Projects  in  Progress  at the End of Fiscal              55
              1987 by Region/State

2.5-1         Facilities  Subject  to CERCLA Section 121(c)                   60

2.6-1         Cost Recovery Activities                                      62

2.6-2         Value of  Cost Recovery Settlements by Fiscal Year             63

5.3-1         Fiscal 1987 Contract  Awards                                    85

5.3-2         Site Samples Analyzed for  Remedial Investigations/
              Feasibility Studies by Fiscal Year                            86

5.4-1         Fiscal 1987 Superfund Program Resources to Regional           89
              Offices

5.4-2         Historical  Superfund  Program Resources to Regional Offices    90

5.4-3         Fiscal 1987 Superfund Resources by Program Function           92

5.4-4         Fiscal 1987 Superfund Resources by EPA Office and             93
              Function

5.4-5         Historical  Superfund  Program Resource Distribution            94

5.4-6         Fiscal 1987 Superfund Interagency Support Resources           97

10.2-1        Federal Facilities  Listed  on the Initial Hazardous           132
              Waste Compliance  Docket

10.2-2        Distribution by Region of  Federal Facilities on the          133
              Hazardous Waste Compliance Docket

10.7-1        EPA Facilities on the Hazardous Waste Compliance             136
              Docket
                                      411
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                 Progress Toward Implementing Superfund: Fiscal Year 1987


                                LIST OF EXHIBITS
                                    (continued)


Exhibit
Number                            Title of Exhibit                              Page

11.3-1        Minority Firm  Share of  Superfund Contracting by Type,         143
              Fiscal Year  1987

13.2-1        EPA Superfund  Staffing  Requirements by Fiscal Year            153

13.2-2        EPA Superfund  Funding Requirements by Fiscal Year             154

13.2-3        Summary of EPA Superfund Workload by Fiscal Year              155

13.2-4        EPA Superfund  Interagency Funding by Fiscal Year              156

13.3-1        Annual Superfund  Resource Needs of Other Federal              159
              Departments  and Agencies

13.3-2        Federal Superfund Implementation Funding                      160
              Requirements by Fiscal  Year

13.3-3        Federal Superfund Implementation Staffing                     161
              Requirements by Fiscal  Year

              EPA Headquarters  and  Regional Superfund Offices               169
                                      412
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
ABNs

ANPRM

ARARs

ARCS

ASTSWMO


ATS

ATSDR

CA

CDC

CERCLA


CERCLIS

CERI

CERT

CIS

CLP

DDT

DOC

DOH

DOI

DOJ

DOL

DOT
                  APPENDIX H

             LIST OF ABBREVIATIONS


Acid and Base/Neutral Compounds

Advance Notice of Proposed Rulemaking

Applicable or Relevant and Appropriate Requirements

Alternative Remedial Contract Strategy

Association  of  State and Territorial Solid  Waste Management
Officials

Action Tracking System

Agency for Toxic Substances and Disease Registry

Cooperative Agreement

Centers for Disease Control

Comprehensive   Environmental   Response,    Compensation,   and
Liability Act of 1980, as amended

CERCLA Information System

Center for Environmental Research Information

Council of Energy Resource Tribes

Contract Information System

Contract Laboratory Program

Dichloro-diphenyl-trichloroethane

Department of Commerce

Department of Health

Department of the Interior

Department of Justice

Department of Labor

Department of Transportation
                                      413
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
EDA

EE/CA

EHS

EMSL

EPA

ERGS

ERNS

ERT

ESAT

FAA

FDER

FEMA

FIFRA

FIT

FMS

FY

GIGS

GSA

HAZMAT

HHS

HRS

HRSD

HSED

IAG
                             LIST OF ABBREVIATIONS
                                   (continued)
Emergency Declaration Area

Engineering Evaluation/Cost Analysis

Extremely Hazardous Substance

Environmental Monitoring Services Lab

Environmental Protection Agency

Emergency Response Cleanup Services

Emergency Response Notification System

Emergency Response Team

Environmental Services Assistance Teams

Federal Aviation Administration

Florida Department of Environmental Regulation

Federal Emergency Management Agency

Federal Insecticide, Fungicide,and Rodenticide Act

Field Investigation Team

Financial Management System

Fiscal Year

Grant Information Control System

General Services Administration

Hazardous Materials

Department of Health and Human Services

Hazard Ranking System

Hazardous Response Support Division

Hazardous Site Evaluation Division

Interagency Agreement
                                      414
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                 Progress Toward Implementing Superfund: Fiscal Year 1987
                             LIST OF ABBREVIATIONS
                                    (continued)
IG          - -  Office of  the  Inspector  General

IRCN        - -  Interagency Report  Control  Number

IRM         - -  Initial Remedial Measure

IWT         --  International  Waste Technologies

LOE         --  Level of Effort

MBDA        --  Minority Business Development Agency

MBDCs       --  Minority Business Development Centers

MBEs        --  Minority Business Enterprises

MCLs        --  Maximum Contaminant Levels

MOU         - -  Memorandum of  Understanding

NAAG        --  National Association of  Attorneys  General

NAMC        --  National Association of  Minority Contractors

NBARs       --  Nonbinding Allocations of Responsibility

NCP         --  National Contingency Plan

NEIC        - -  National Enforcement Investigation Center

NEPA        - -  National Environmental Policy Act

NGA         --  National Governors'  Association

NIEHS       --  National Institute  for Environmental Health Sciences

NOAA        - -  National Oceanic and Atmospheric Administration

NPL         --  National Priorities List

NPRM        --  Notice of  Proposed  Rulemaking

NRC         --  National Response Center

NRT         --  National Response Team

NTP         - -  National Toxicology Program
                                      415
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                 Progress Toward Implementing Superfund:  Fiscal Year 1987
NYSDEC

O&M

OAQPS

OECM

OERR

OHRM

OMB

OMSE

OPA

OPMT

ORD

ORP

OSC

OSDBU

OSHA

OSR

OSWER

OWPE

PA

PADER

PAHs

PASS

PCBs

POTWs
                             LIST OF ABBREVIATIONS
                                   (continued)
New York State Department of Environmental Conservation

Operation and Maintenance

Office of Air Quality Planning and Standards

Office of Enforcement and Compliance Monitoring

Office of Emergency and Remedial Response

Office of Human Resource Management

Office of Management and Budget

Office of Management Systems Evaluation

Office of Policy Analysis

Office of Program Management and Technology

Office of Research and Development

Office of Radiation Programs

On-Scene Coordinator

Office of Small and Disadvantaged Business Utilization

Occupational Safety and Health Administration

Office of Standards and Regulations

Office of Solid Waste and Emergency Response

Office of Waste Programs Enforcement

Preliminary Assessment

Pennsylvania Department of Environmental Resources

Polycyclic Aromatic Hydrocarbons

Procurement Automated Source System

Polychlorinated Biphenyls

Publicly-Owned Treatment Works
                                      416
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                 Progress Toward Implementing Superfund: Fiscal Year 1987
PRP

RA

RAC

RCRA

RD

REM

RI/FS

ROD

RPM

RQ

RRTs

SARA

SBA

SCAP

SCDHEC

SDC

SI

SITE

SMOA

SPMS

STSP

SWCB

TAGs

TAT
                             LIST OF ABBREVIATIONS
                                    (continued)
Potentially Responsible Party

Remedial Action

Response Action Contractor

Resource Conservation and Recovery Act

Remedial Design

Remedial Planning  (Contract)

Remedial Investigation/Feasibility Study

Record of Decision

Remedial Project Manager

Reportable Quantity

Regional Response Teams

Superfund Amendments and Reauthorization Act  of  1986

Small Business Administration

Superfund Comprehensive Accomplishments Plan

South Carolina Department of Health and Environmental Quality

Settlement Decision Committee

Site Inspection

Superfund Innovative Technology Evaluation

Superfund Memorandum of Agreement

Strategic Planning and Management System

Superfund Technical Support Program

State Water Control Board

Technical Assistance Grants

Technical Assistance Team
                                      417
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                 Progress Toward Implementing Superfund: Fiscal Year 1987
                             LIST OF ABBREVIATIONS
                                    (continued)
TCE         --  1,1,1-Trichloroethane

TES         - -  Technical Enforcement Support

TPQ         --  Threshold Planning Quantity

TSCA        --  Toxic Substances  Control Act

USCG        --  United States  Coast Guard

VOCs        --  Volatile Organic  Compounds

VORCE       --  Volume Reduction/Chemical Extraction Process

VORRP       --  Volume Reduction  Research Project

WBEs        --  Women's Business  Enterprises

WQC         --  Water Quality  Criteria
                                       418
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Progress Toward Implementing Superfund: Fiscal Year 1987
             STATE ABBREVIATIONS
AK
AL
AR
AZ
CA
CO
CT
DE
FL
GA
GU
HI
IA
ID
IL
IN
KS
KY
LA
MA
MD
ME
MI
MN
MO
MS
Alaska
Alabama
- - Arkansas
- - Arizona
California
Colorado
Connecticut
Delaware
- - Florida
Georgia
Guam
-- Hawaii
Iowa
Idaho
-- Illinois
Indiana
Kansas
Kentucky
Louisiana
Massachusetts
Maryland
Maine
Michigan
Minnesota
Missouri
Mississippi
MT
NC
ND
NE
NH
NJ
NM
NV
NY
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VA
VT
WA
WI
WV
WY
                                     Montana
                                     North Carolina
                                     North Dakota
                                     Nebraska
                                     New Hampshire
                                     New Jersey
                                     New Mexico
                                     Nevada
                                     New York
                                     Ohio
                                     Oklahoma
                                     Oregon
                                     Pennsylvania
                                     Puerto Rico
                                     Rhode Island
                                     South Carolina
                                     South Dakota
                                     Tennessee
                                     Texas
                                     Utah
                                     Virginia
                                     Vermont
                                     Washington
                                     Wisconsin
                                     West Virginia
                                     Wyoming
                      419
                                  •f US GOVENMENT PRINTING OFFICE' 1989-648-163/00301
-------
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-------
U.S. Environmental Protection
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th floor
Chicago, It  60604-3590
-------
1.0   EXECUTIVE SUMMARY


2.0   RESPONDING TO RELEASES OF HAZARDOUS SUBSTANCES


3.0   THE EEDERAL-STATE PARTNERSHIP IN IMPLEMENTING CERCLA


4.0   PUBLIC INFORMATION AND COMMUNITY' RELATIONS


5.0   PROGRAM AND IMPLEMENTATION SUPPORT


6.0   EPA RULEMAKING ACTIONS TO IMPLEMENT CERCLA


7.0   DEVELOPMENT AND EVALUATION OF PERMANENT TREATMENT TECHNOLOGIES


8.0   TECHNOLOGICAL AND HEALTH-RELATED RESEARCH AND DEVELOPMENT
     AND TECHNICAL ASSISTANCE

9.0   EPA AND  AGENGY FOR TOXIC' SUBSTANCES AND DISEASE REGISTRY
     HEALTH-RELATED ACTIVITIES


10.0  IMPLEMENTATION OF THE FEDERAL FACILITIES REQUIREMENTS


11.0  MINORITY" FIRM PARTICIPATION IN SUPERFUND CONTRACTING


12.0  THE NATIONAL RESPONSE TEAM AND REGIONAL RESPONSE TEAMS


13.0  EXECUTIVE  BRANCH ESTIMATE OF RESOURCES NEEDED TO COMPLETE
     SUPERFUND IMPLEMEN I ATION


14.0  OTHER EPA ACTIONS TO IMPLEMENT CERCLA


APPENDIX A: STATUTORY LANGUAGE


APPENDIX B: REMOVAL ACTIONS


APPENDIX C : ROD DESCRIPTIONS


APPENDIX 1): Rl/FS AND RA STATUS REPORT


APPENDIX E: FR DOCUMENTS


APPENDIX F: INSPECTOR GENERAL REPORT


APPENDIX G: LIST OF EXHIBITS


APPENDIX H: ABBREVIATIONS
-------