United States      Solid Waste and      EPA/540/8-90/004
Environmental Protection   Emergency Response    April 1990
Agency         (OS-240)


Superfund



Progress Toward


Implementing Superfund


Fiscal Year 1988
Report to Congress

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                                           EPA/540/8-90/004
                                                April 1990
       PROGRESS  TOWARD IMPLEMENTING SUPERFUND
                   FISCAL YEAR 1988
                  REPORT TO CONGRESS

                     REQUIRED BY

                SECTION 301 (h) OF  THE
COMPREHENSIVE ENVIRONMENTAL  RESPONSE, COMPENSATION,
        AND LIABILITY ACT  (CERCLA) OF 1980,
                  AS  AMMENDED BY THE
              SUPERFUND AMENDMENTS AND
         REAUTHORIZATION ACT  (SARA)  OF 1986
      OFFICE OF EMERGENCY AND REMDIAL RESPONSE
        U.S. ENVRIONMENTAL PROTECTION AGENCY
                      APRIL 1990
                        U.S. Environmental Protection Agency
                        Region 5, Library (PL-12J)
                        77 West Jackson Boulevard, 12th Floor
                        Chicago, IL  60604-3590

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    NOTICE
This Report  to  Congress  has  been subjected to the United  States  Environmental
Protection  Agency's review  process and  approved for  publication  as an  EPA
document.   For  further information about  this  Report,  contact the  Policy and
Analysis  Staff  in the Office  of Program Management, Office of  Emergency and
Remedial  Response at  202/382-2182.   Individual  copies of  the  Report can be
obtained from the Office  of Research and Development Publications by writing to:
26 West Martin Luther King Drive, Cincinnati, Ohio 45268, or by calling 513/569-
7562.

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  FOREWORD

     We are pleased to submit the Environmental Protection Agency's Annual Report
on the progress made by the Agency during fiscal year 1988 in implementing the
Comprehensive Environmental Response,  Compensation,  and Liability Act (CERCLA
or Superfund), as  amended by  the  Superfund Amendments and Reauthorization Act
(SARA) of 1986.  This Report,  and the information it contains,  is required by
CERCLA  section  301(h).    The  Report  includes  a description of  minority firm
participation in  Superfund contracts,  and  of our efforts  to  encourage their
participation, as required by section 105(f).   The Report meets the requirement
of section 301(h)(l)(E)  for an annual update  on progress  being  made on sites
subject to review under section 121(c).  In addition to  satisfying the section
301(h)(l)(E)  requirement,  this Report satisfies similar  reporting requirements
of section 121(c).   The  report of  the EPA Inspector General on his findings
concerning the reasonableness  and accuracy of  the  information  in this Report
related to EPA's activities,  as required by section 301(h)(2),  is included as
Appendix F.

     Significant progress was made in field activities during the fiscal year.
The Agency completed a  record breaking 282  removal  actions using CERCLA funds
or enforcement authorities.  In addition, EPA completed  remedial actions at 24
sites and started 72 remedial actions.  More than 150 Records of Decision were
signed during the  fiscal  year,  twice the number signed  in FY87.   Much of the
Agency's progress was characterized  by efforts to satisfy statutory schedules
and requirements.  For  example, the  Agency completed almost 1,000 preliminary
assessments during the  first  quarter of FY88.   This effort allowed the Agency
to meet the statutory requirement that preliminary assessments be conducted by
January 1988  on all sites entered  into  the  CERCLA Information  System  as of
October 1986.  The Agency  strengthened  its enforcement efforts,  increasing the
percentage of clean-up  activities that are funded  by potentially responsible
parties and negotiating  more settlement  agreements during FY88 than in any prior
fiscal year.   The  Agency  also  put the final touches on  the proposed revisions
to the hazard ranking system (HRS) and the National Contingency Plan (NCP).  The
revisions to  both the HRS  and the NCP  are required by CERCLA, as amended by SARA,
and were published in the  Federal Register for public review and comment shortly
after the end of FY88.

     In addition to  providing an overall perspective on progress  in the past
fiscal year,  the  Report also contains  information  that Congress specifically
requested in section 301(h)(l), including a detailed description  of each of the
152 Records of Decision that were  signed in fiscal  year 1988;  a report on the
status of remedial actions, including enforcement activity, in progress at the
end  of  the fiscal  year;   and  an  evaluation  of newly developed  feasible and
achievable permanent treatment  technologies.
William K. Reilly  ^\^___^/         Don R- clay
Administrator                           Assistant Admin^strxfor for
                                        Solid Waste and emergency Response
                                       iii

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                    Progress Toward Implementing Superfund: Fiscal Year 1988






                                          CONTENTS








                                                                                          Page



      FOREWORD  	     iii




      LIST OF EXHIBITS  	    xviii



      ACKNOWLEDGEMENTS	     xri



1.0    EXECUTIVE SUMMARY	       1



      Fiscal 1988 Accomplishments	       1



          Removal Program Activities	       8



          Remedial Program Activities 	       8



          Pre-Remedial Program Activities	       9



          Enforcement Program Activities  	      10



          Major Rulemakings	      11



          Program Management Initiatives	      11



           Contract Initiatives   	      12



          Minority Firm Participation in Superfund Contracting	      12



          Federal Facility Compliance with Superfund Requirements	      13



          EPA Partnership with States and Indian Tribes	      13



          Public Participation	      13



          Development of Treatment Technology  	      13



2.0    INTRODUCTION  	      15



      2.1   Organization of the Report	      15



      22   Statutory Requirements for the Report  	      15



3.0    RESPONSES AT SITES WITH HAZARDOUS SUBSTANCE RELEASES	      17



      3.1   Removal Actions 	      17



          Status Report on Removal Actions	      17



           3.1.1  Types  of Removal Actions   	      21



          3.1.2  The Removal Action Process	      22

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         Progress Toward Implementing Superfund:  Fiscal Year 1988
                                CONTENTS
                                (continued)
                                                                                  Page

      3.12.1  Emergency and Time-Critical Removals	      22

      3.1.2.2  Non-Time-Critical Removals	      22

3.13  The Removal Actions Universe Study	      22

3.1.4  Removal Actions Taken During Remedial Actions  	      24

3.1.5  Removal Action Guidance	      24

      3.1.5.1  Superfund Removal Procedures, Revision #3  	      25

      3.1.52  Consistency Exemption from the Statutory Limits on Removal Actions      25

      3.1.53  Removal Cost Management Manual  	      25

      3.1.5.4  Temporary Relocation in the Removal Program  	      25

      3.1.5.5  Engineering Evaluation/Cost Analysis	      26

      3.1.5.6  Nationally Significant or Precedent-Setting Removals at Non-NPL Sites      26

      3.1.5.7  Removal Action Levels at Drinking-Water Contamination Sites	      26

      3.1.5.8  File Management	      26

      3.1.5.9  Post-Removal Site Control	      26

The Remedial Program	      27

32.1  Remedial Action	      27

      32.1.1  The Remedial Action Process	      27

      32.12  Completed Projects	      29

      32.13  Site Operation and  Maintenance	      33

      32.1.4  Sites to be Reviewed Under CERCLA Section 121(c)  	      34

322  Remedial Investigations/Feasibility Studies	      36

      322.1  The Remedial Investigation/Feasibility Study Process	      36

             Operable Units	      40
                                     VI

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                    Progress Toward Implementing Superfund: Fiscal Year 1988
                                          CONTENTS
                                           (continued)
                 3.222  Streamlining the Remedial Investigation/Feasibility
                        Study Process  	      41

                        Remedial Investigation/Feasibility Study Cost Study  	      41

                        Key Management Initiatives	      42

                 3223  Strategy to Meet the CERCLA Section 116 Targets	      42

                 32.2.4  Remedial Investigation/Feasibility Study Guidance  	      45

           323  Status Report on Remedial Investigations, Feasibility Studies,
                 and Remedial Actions  	      45

           32.4  Remedy Selection  	      45

                 Summary of Remedies Selected in Fiscal 1988	      51

                 Remedy  Selection Guidance Documents	      54

                 Applicable or Relevant and Appropriate Requirements	      55

           32.5  Remedial Design	      56

                 32.5.1  The Remedial Design Process	      56

      33   Response Action Work Force	      56

           33.1  Worker  Protection Standards  	      57

4.0    SITE DISCOVERY AND ASSESSMENT	      61

      4.1   The Site Discovery and Assessment  Process	      61

      42   Notification	      63

           42.1  National Response Center  	      63

           422  Reportable Quantities  	      63

      43   The Inventory  of Sites (CERCLIS)	      65

      4.4   Preliminary Assessments	      66

           4.4.1  Statutory Goals Under CERCLA Section 116	      66

           4.42  Reassessment of Low-Priority Sites  	      66

           4.43  Preliminary Assessment Guidance	      66

           4.4.4  Prescore  	      67
                                               vii

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                                           CONTENTS
                                            (continued)
                                                                                              fage

      4.5  Site Inspections	      68

           4.5.1   Screening Site Inspections  	      68

           4.5.2   Listing Site Inspections  	      68

5.0    THE NATIONAL PRIORITIES LIST OF SITES  	      71

      5.1  Sites Added to the National Priorities List	      71

           5.1.1   Methods for Listing Sites	      71

      52  Sites Deleted from the National Priorities List	      76

      53  Revisions to Listing Policy	      79

           53.1   Deferred Listing Policy  	.•	      79

           532   Additions to Criteria for Listing RCRA Sites  	      79

           533   Revisions to  the Unwillingness and Inability-to-Pay Criteria	      80

                  533.1 Unwillingness  	      80

                  5332 Inability	      81

6.0    ENFORCEMENT PROGRAM ACTIVITIES	,	      83

      6.1  Overview of Enforcement Activities	      83

           6.1.1   Potentially Responsible Party Involvement	      83

           6.12   Guidance on Potentially Responsible Party Involvement  	      85

           6.13   Enforcement Under CERCLA Section 106	      85

                  Progress During Fiscal 1988	,      85

                  Initiatives to Increase the Number of CERCLA Section 106 Actions	      86

                  Key Action	      86

           6.1.4   Interaction with the Department of Justice	      88
                                                VIII

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                                          CONTENTS
                                           (continued)


                                                                                            Page

      62   Negotiated Settlements  	      88

           6.2.1  Major Settlements in Fiscal 1988	      88

           6.22  Notice Procedures	      92

                 General Notice  	      92

                 Special Notices  	      92

           623  Arbitration	      93

           62A  De Minimis Settlements  	      93

           6.2.5  Covenants Not to Sue 	      94

           6.2.6  Mixed Funding	.	      94

           62.1  Nonbinding Allocations of Responsibility  	      95

      63   The Cost Recovery Program Under CERCLA Section 107	      96

           Progress in Fiscal 1988	      96

           Background	      96

           Cost Recovery Program Guidance Documents	      98

      6.4   Orders Under CERCLA Section 109 for CERCLA Section 103 Violations	     100

      6.5   National Enforcement  Investigations Center Activities  	     100

7.0    THE EPA PARTNERSHIP WITH STATES AND INDIAN TRIBES	     103

      7.1   Overview	     103

      7.2   State  Involvement Regulations	     103

           7.2.1  State Involvement Under the Proposed Revised  National
                 Contingency Plan 	     103

           7.2.2  CERCLA Section lll(o)  Notification Procedures  	     104

      7.3   Procedures for Involvement of State and Local Governments and
           Indian Tribes    	     104

           7.3.1  Cooperative Agreements with States	     104

           73.2  Cooperative Agreements with Local  Governments	     105

           733  Core Program Cooperative Agreements	     105


                                               ix

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                                          CONTENTS
                                          (continued)
      7.4   Superfund Memoranda of Agreement	     105

      7.5   State Assurance of Capacity	     105

      7.6   Indian Tribes	     107

           7.6.1  Applicability of State Participation Regulations to Indian Tribes	     108

           1.62  Cooperative Agreements with Indian Tribes	     108

           7.63  Indian Outreach Program	     108

8.0    COMMUNITY RELATIONS AND PUBLIC INFORMATION	     109

      8.1   Community Relations	     109

           8.1.1  Community Relations Requirements for Removal Actions	     109

                 8.1.1.1  The Community Relations Plan  	     109

                 8.1.12  The Public Comment Period  	     110

           8.12  Community Relations Requirements for Remedial Actions	     110

           8.13  Technical Assistance Grants Under CERCLA Section 117(e)  	     Ill

                 8.13.1  Purpose of the Technical Assistance Grant Program  	     Ill

                 8.132  Guidance on Technical Assistance Grants  	     112

      82   Public Information	     113

           82.1  Resource Conservation and Recovery Act/Superfund Hotline	     113

           822  Superfund Docket and Information Center	     113

           823  Public Information  Center	     114

           82.4  Hazardous Waste Ombudsman Program	     114

9.0    EPA SUPERFUND PROGRAM ADMINISTRATION	     117

      9.1   Fiscal 1988 Superfund Resource Utilization 	     117

           9.1.1  Overview	     117

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              Progress Toward Implementing Superfund:  Fiscal Year 1988


                                    CONTENTS
                                     (continued)


                                                                                      Page

     9.12  EPA Superfund Program Activities  	      120

           Hazardous Substance Response	      120

           Enforcement	      120

           Management and Support	      120

           Research and Development  	      124

     9.13  Other Executive Branch Department and Agency Superfund Activities	      124

           Department of the Interior	      125

           Department of Transportation	      125

           Department of Health and Human Services	      125

           Department of Commerce  	      126

           Department of Justice	      126

           Department of Labor  	      127

           Federal Emergency Management Agency	      127

92   Superfund Contracting	      127

     92.1  Overview	      127

     922  Contract Laboratory Program	      128

           Environmental Services Assistance Team Contracts	      130

     923  Response Support Contracts	      132

           Removal Support Contracts  	      132

           Remedial Support Contracts	      133

     92.4  Contract Operations Review and Assessment Staff	      134

93   Training Activities 	      134

     93.1  Overview	      135

           Future of Training Programs:  OSWER's Five-Year Strategy  	      135
                                         XI

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                                     CONTENTS
                                     (continued)


                                                                                       Page

     933.  Meeting Critical OSWER Training Needs in Fiscal 1988	     136

           OSWER Annual Training Plan for Fiscal 1988  	     137

           OSWER Training and Technology Transfer Needs Assessment	     137

           OSWER Training Course Catalogue  and Training Calendar  	     137

     93.3  Priority Training Program Goals and  Related Training Courses	     138

           Management Improvements in Technical and Programmatic Capabilities	     138

           Environmental Response Team Training	,	     138

           Training on Revised Program Guidance  	     139

           Compliance with Other Statutes and Regulations  	     139

           Health and Safety	     139

           Ground-Water Training Initiatives	     140

           Risk Assessment	     140

           Emergency Preparedness	     140

           Technology Transfer	     141

     93.4  Organizational  Improvements in  Fiscal 1988	     141

           Alternative Training Delivery Methods	     141

           Superfund Work Force Planning Project  	.,	     141

           Expanded Superfund Curriculum	     142

9.4   Management and Information Systems	     143

     9.4.1  CERCLIS	     143

           Modifications to CERCLIS  	     144

           Areas for Change in CERCLIS	     146

     9.4.2  Strategic Planning and Management System/Action Tracking System 	     147

     9.43  Superfund Enforcement Tracking System	     147

     9.4.4  Case  Budget System	     148

     9.4.5  Cost  Documentation Monitoring  System	     148


                                          xii

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                                     CONTENTS
                                     (continued)


                                                                                        Page

     9.4.6  Financial Management System  	     148

     9.4.7  OSWER Internal Directives System	     148

           OERR Superfund Directives System	     148

     9.4.8  Emergency Response Notification System  	     149

     9.4.9  Accident Release Information Program	     150

     9.4.10 Acute Hazardous Events Data Base	     150

     9.4.11 Oil and Hazardous Materials Technical Assistance Data System  	     150

9.5   General Rulemakings   	     151

     9.5.1  Revision of the National Contingency Plan and the Hazard
           Ranking System  	     151

           9.5.1.1 National Contingency Plan	     151

                  Remedy Selection  	     152

                  Early Action	     152

                  Applicable or Relevant and Appropriate Requirements	     152

                  Role of States	     152

                  Statutory Revisions to Removal Action Time and Dollar
                  Limitations  	     153

                  Community Relations	     153

           9.5.1.2 Hazard Ranking System  	     153

                  HRS Pilot Program  	     154

                  Potential to Release Component	     154

                  On-Site  Exposure  	     154

                  Surface-Water Contamination	     154

                  Human  Exposure to  Contaminants	     155
                                         xiii

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                                           CONTENTS
                                           (continued)


                                                                                            Page

           952  Administrative Record	      155

                 9.5.2.1  Purpose of the Administrative Record	      155

                 9.5.2.2  Availability of the Administrative Record	      156

           9.53  Reportable Quantities  	      156

                 9.53.1  Reportable Quantity Adjustment Final Rule	      157

                 9.532  Radionuclides Reportable Quantity Adjustment	      157

           9.5.4  Federally Permitted and Continuous Releases  	      158

                 9.5.4.1  The Continuous Release Proposed Rule	      158

                 9.5.4.2  The Federally Permitted Release Proposed Rule  	      158

           9.5.5  The Designation Proposed Rule	      158

           9.5.6  Reimbursement to Local Governments	      159

           9.5.7  Technical Assistance Grants	      159

           9.5.8  Citizen Awards for Information on Criminal Violations Under Superfund ...      159

           9.5.9  Other Rulemakings  . . . .	      160

10.0   MINORITY FIRM PARTICIPATION IN SUPERFUND CONTRACTING	      161

      10.1 Identifying Qualified Minority Firms	      161

      10.2 Efforts to Encourage Participation 	      161

11.0   TECHNOLOGY-RELATED RESEARCH AND DEVELOPMENT	      167

      11.1 Overview	      167

      11.2 The Superfund Innovative  Technology Evaluation Program"	      168

           112.1 The Demonstration  Program	      168

           1122 The Emerging Technologies Program	      169

           11.23 Innovative  Development and Evaluation Program	      171

           11.2.4 Measurement and Monitoring  Technologies Development Program	      172

           112.5 Technology Transfer/Clearinghouse Program	      172
                                               xiv

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                    Progress Toward Implementing Superfund:  Fiscal Year 1988
                                          CONTENTS
                                           (continued)
      113  International Survey of Treatment Technologies  	     173

      11.4  Research Grants/University Hazardous Substance Research Centers  	     173

           11.4.1 University Research Grants Program	     174

           11.42 University Hazardous Substance Research Centers	     174

      11.5  Technology Support Project	     175

           11.5.1 Technology Transfer/Information Clearinghouse  	     175

           11.52 Career Enhancement and Development	     176

12.0   HEALTH-RELATED RESEARCH AND DEVELOPMENT  	     177

      12.1  Overview	     177

      122  EPA Health-Related Research Program	     177

           122.1 Health Effects, Risk Assessment, and Detection Research  	     177

           1222 Toxics Integration Branch  	     179

      123  The Agency for Toxic Substances and Disease Registry  	     180

      12.4  The National Institute of Environmental Health Sciences	     181

13.0   EXECUTIVE BRANCH ACTIONS TO IMPLEMENT CERCLA 	     183

      13.1  The National Response System	     183

           13.1.1 The National Response Center  	     183

           13.12 Regional Response Teams  	     183

           13.13 The National Response Team	     184

      132  Federal Facilities Program  	     186

           132.1 Federal Agency Hazardous Waste Compliance Docket	     186

           1322 Federal Facility Preliminary Assessments/Site Inspections	     187

           1323 Federal Facilities Proposed for and Listed on the National
                 Priorities List	     187
                                               xv

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                    Progress Toward Implementing Superfund: Fiscal Year 1988
                                         CONTENTS
                                          (continued)
           132.4  Federal Real Property Transfer Regulations	      189

           132.5  Federal Facility Agreements Under CERCLA Section 120	      ISO

           132.6  Report to Congress on EPA Responsibilities Under CERCLA
                 Section 120 (e) (5)	      191

14.0   EXECUTIVE BRANCH ESTIMATE OF RESOURCES NEEDED TO COMPLETE;
      SUPERFUND IMPLEMENTATION	      153

      14.1  Introduction 	      193

      142  EPA Estimate of Resources Necessary to Complete Superfund Implementation  ....      194

           Direct  Site Support  	     195

           Program Support	     196

           Site-Related  Work	     196

           142.1  Remedial Program Costs	      196

           1422  Cost  Recovery Revenues	      197

           1423  Direct Clean-up Actions by Potentially Responsible Parties 	      197

      143  Estimation of Resource Needs, Beyond Fiscal 1990, to Complete the
           Cleanup of the Existing National Priorities List	      197

           143.1  Estimated Cost to  Complete Current National Priorities List Sites	      200

           1432  Major Program Elements Represented in the Model	      202

                 Currently Active Sites  	     202

                 New Site Starts  	     203

                 Who  is Responsible? -  Who Pays?	     203

                 Factors Related to Remedial Action Costs  	     204

                 Program  Support and Other Agency Costs	     205

      14.4  Other Executive Branch Department and Agency Estimates of Resources
           Necessary to Complete Superfund Implementation  	      205
                                              xvi

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                    Progress Toward Implementing Superfund:  Fiscal Year 1988


                                          CONTENTS
                                           (continued)


                                                                                           Page

APPENDICES

      A.   Status of Remedial Investigations, Feasibility Studies, and Remedial
           Actions in Progress on September 30, 1988  	     A-l

      B.   Record of Decision Abstracts	     B-l

      C.   Federal Register Notices of Superfund Program Actions Taken in Fiscal 1988	     C-l

      D.   Superfund Documents Issued During Fiscal 1988  	     D-l

      E.   Statutory Language for this Report and EPA and  Executive Branch
           Implementation of CERCLA, as Amended by SARA  	     E-l

      F.   EPA Inspector General Report Under CERCLA  Section 301 (h) (2)	     F-l

      G.   List of Sources 	     G-l

      H.   List of Abbreviations  	     H-l
                                              XVII

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                                   LIST OF EXHIBITS


                                                                                            Page

Exhibit 1.0-1 Fiscal 1988 Field Work Accomplishments  	       3

Exhibit 1.0-2 Progress Toward Meeting CERCLA Section 116 Goals	       4

Exhibit 1.0-3 Summary of Fiscal 1988 Superfund Program Activities	       5

Exhibit 1.0-4 Summary of Program Activity by Fiscal Year  	       7

Exhibit 3.1-1 Removal Action Starts and Completions by Fiscal Year  	       18

Exhibit 3.1-2 Fiscal 1988 Removals by State  	       19

Exhibit 3.1-3 The Removal Action  Process	       23

Exhibit 3.2-1 The Remedial Stage of the Superfund Process  	       28

Exhibit 3.2-2 Historical Remedial Action Starts	       29

Exhibit 3.2-3 The Remedial Action Process  	       30

Exhibit 3.2-4 Site Completions During Fiscal 1988	       31

Exhibit 3.2-5 Potential Sites to be Reviewed Under CERCLA Section 121(c) as of
September 30,  1988	       35

Exhibit 3.2-6 Superfund Remedial Investigation/Feasibility Study Starts and
Completions During Fiscal 1988 by Region  	       37

Exhibit 3.2-7 Historical Remedial Investigation/Feasibility Study Starts	       38

Exhibit 3.2-8 The Remedial Investigation/Feasibility  Study Process	       39

Exhibit 3.2-9 Fiscal 1988 Accomplishments at Sites on
the 175 Remedial Action Candidate List   	       43

Exhibit 3.2-10  Progress Toward Meeting the 275 Remedial Investigation/
Feasibility Study Start Target	       44

Exhibit 3.2-11  Status of Ongoing Remedial Investigation, Feasibility Study,
and Remedial Action Projects at the End  of Fiscal 1988  	       46

Exhibit 3.2-12  Distribution of Ongoing Remedial Investigation,
Feasibility Study, and Remedial Action Projects at the End of
Fiscal 1988 by Region and State	       47

Exhibit 3.2-13  Historical Records of Decision Signed	       49

Exhibit 3.2-14  Records of Decision Signed In Fiscal 1988 for
First and Subsequent Operable Units  	       50

Exhibit 3.2-15  The Remedy Selection Process	       52
                                           xvm

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                                   LIST OF EXHIBITS
                                        (continued)
                                                                                            Page
Exhibit 3.2-16 Summary of Remedy Selection in Records of
Decision Signed in Fiscal 1988	       53

Exhibit 3.2-17 Remedies Selected in Historical Records of Decision   	       55

Exhibit 3.2-18 Historical Remedial Design Starts	       57

Exhibit 3.2-19 The Remedial Design Process  	       58

Exhibit 4.0-1 Historical Pre-Remedial Program Accomplishments  	       62

Exhibit 4.1-1 The Site Discovery and Assessment Process	       64

Exhibit 4.4-1 CERCLIS Sites with Preliminary Assessments
Completed Through Fiscal 1988  	       67

Exhibit 4.5-1 Site Inspections Completed through 1988	       68

Exhibit 5.0-1 National  Priorities List Sites by State or Territory
as of September 1988  	       72

Exhibit 5.0-2 Map of National Priorities List Sites	       74

Exhibit 5.1-1 Historical National Priorities List Sites  	       75

Exhibit 5.1-2 The Process for Placement of a Site on
the National Priorities List	       77

Exhibit 5.2-1 Sites Deleted from the National Priorities List	       78

Exhibit 6.0-1 The Sequence of Enforcement Actions in  the Remedial
Process	       84

Exhibit 6.1-1 The Increasing Enforcement Role in Remedial Investigation/
Feasibility Study First Starts   	       87

Exhibit 6.1-2 Administrative  Orders Issued Since the Enactment of SARA  	       87

Exhibit 6.2-1 Number and Value of Superfund Settlements in Fiscal 1988  	       89

Exhibit 6.2-2 Number and Value of Superfund Settlements,  Fiscal 1980
Through Fiscal 1988	       89

Exhibit 6.3-1 Value of  Cost Recovery Settlements by Fiscal  Year   	       97

Exhibit 6.3-2 Number and Value of Cost Recovery Referrals to EPA Headquarters	       97

Exhibit 6.3-3 Cost Recovery Activities	       98
                                           xix

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               Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   LIST OF EXHIBITS
                                       (continued)
Exhibit 8.1-1 Communities Receiving Technical
Assistance Grants in Fiscal 1988	     112

Exhibit 9.1-1 Fiscal 1988 Superfund Program Resources to Regional Offices	     118

Exhibit 9.1-2 Historical Superfund Program Resources to Regional Offices  	     119

Exhibit 9.1-3 Superfund Fiscal 1988 Resources by Program Function	     121

Exhibit 9.1-4 Fiscal 1988 Superfund Resources by EPA Office and Function	     122

Exhibit 9.1-5 Historical Superfund Program Resource Distribution	     123

Exhibit 9.1-6 Fiscal 1988 Superfund Interagency Support Resources	     126

Exhibit 9.2-1 Fiscal 1988 Contract Awards	     129

Exhibit 9.2-2 Contract Laboratory Program Superfund Analytical
Services for Fiscal 1988	     130

Exhibit 9.2-3 Contract Laboratory Program Analytical Data
Bases  and Data Support Systems	     131

Exhibit 11.2-1 Technologies Accepted Under the Site
Demonstration Program for Fiscal 1988   	     170

Exhibit 11.2-2 Emerging Technologies Program Participants	     171

Exhibit 13.1-1 National Response Team Members	     185

Exhibit 13.2-1 Federal Facilities Added to the Federal Agency Hazardous
Waste  Compliance Docket by the First Update	     188

Exhibit 13.2-2 Distribution by Region of Federal Facilities Added to the
Federal Agency Hazardous Waste Compliance Docket by the First Update	     189

Exhibit 13.2-3 EPA Facilities on the Federal Agency Hazardous Waste
Compliance Docket	     192

Exhibit 14.2-1 Summary of EPA Superfund Actual/Planned Actions by
Fiscal  Year	     198

Exhibit 14.2-2 EPA Superfund Funding Requirements by Fiscal Year	     199

Exhibit 14.2-3 EPA Superfund Staffing Requirements in Workyears by Fiscal Year	     200

Exhibit 14.3-1 Estimate of Outyear Liability to Complete  the Existing NPL	     201

Exhibit 14.4-1 CERCLA Resource Needs  and Interagency Funding for Other Federal
Departments and Agencies	     207

Exhibit of Headquarters and Regional Superfund Offices   	     214


                                           xx

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                              ACKNOWLEDGEMENTS


     Completing this second annual Report  to  Congress required the cooperation
and  contributions of  many  staff members  associated  with the  Environmental
Protection Agency and other Federal departments and agencies. In particular, the
Agency appreciates the  contributions  made by Karen Argain, Joan Barnes, Jonathan
Bates, Mike Carter, Beth Caldwell, Kevin Donovan, Dave Evans, Jim Fary (project
manager),  Janet  Grubbs, Belinda  Holmes, Philip Jalbert,   Irene Johnson,  Sven
Kaiser,  Melanie  LaForce,   Mary  Latka,  Ceilanne  Libber,  Trudy  Link,  Tina
Maragousis, George Mori, Terry  Ouverson, Sandra Panetta,  Caroline  Previ, Linda
Sotherland,  Dave  Swack, Louis  Trouche,  Betti VanEpps,  Hubert Watters,  Jeff
Weinerman, Arthur Weissman, Esther Williford,  Jan  Wine,  Jim Woolford, and many
others whose collective efforts made this Report possible.
                                      xxi

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
1.0   EXECUTIVE SUMMARY

     The Environmental  Protection Agency (EPA or the Agency)  made significant
progress  in  implementing  Superfund  and  cleaning  up   the   nation's  worst
contaminated sites during FY88.  Section 301(h)  of  CERCLA,  as  amended by SARA,
requires EPA to prepare and submit to Congress an annual report on the progress
made towards  implementing Superfund.   This  second  annual Report  to Congress
builds  on  the  information contained  in  the  original fiscal  1987  report.   It
provides an overview of EPA's progress  in implementing a wide range of Superfund
program  activities  during  fiscal  1988  and  information  on  specific  program
activities as required by the  statutory  language.   EPA  completed drafting this
Report  before   issuing  the  study  commissioned by  Administrator  Reilly,  A
Management Review of the Superfund Program,  and it,  therefore,  does not contain
information on  Agency progress toward implementing recommendations  from that
s tudy.

     The primary focus of the  Superfund  program  has been  on the actual cleanup
and remediation of hazardous substance  releases and contaminated sites.  Cleanup
under the Superfund program is achieved  through  two  types of  response actions,
shorter-term removal  actions   and  longer-term remedial actions.    This  Report
documents the Agency's progress in implementing Superfund during the fiscal year.
Specifically, the Agency has sought to:

     •   Accelerate the pace of Superfund clean-up actions;

     •   Implement the use of more permanent  remedies and intensify
         technology research and development;

     •   Strengthen Superfund enforcement activities;

     •   Improve the program management  infrastructure;

     •   Implement more efficient Superfund contracting procedures; and

     •   Increase the participation of states, Indian Tribes, and  local
         communities in the Superfund program.

Fiscal 1988 Accomplishments

     Many Superfund program accomplishments  in FY 1988 were significantly higher
than those for  FY 1987,  with  removal and remedial actions  up  overall.   In the
remedial program work was underway  at  580  of  the 797 sites listed as final on
the National  Priorities  List  (NPL),  versus  533 sites  in FY87.   The  Agency
completed 282 removal actions,  64  at proposed  or  final NPL sites, and it started
328  removal actions.   The number of starts  and completions are  both records.
EPA also completed 31 remedial action  (RA)  projects  and started 72, the latter
a program high.

     The remedial  program witnessed other  major achievements.   A record 132
remedial action  (RA)  projects  were in progress,  nearly a  70  percent increase
over the 79  in  progress at the end of the  last  fiscal  year.   FY  1988 saw the
signing of 152  records  of decision (RODs)  during the year.  Also,  a  record 99

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


remedial designs  (RD)  had  been started by year-end.  Exhibit 1.01  illustrates
the Agency's field work accomplishments for FY88.

     Accomplishments   attributable   to   enforcement  program   actions   were
significantly higher this  fiscal  year  than the last fiscal year.   Potentially
responsible parties  (PRPs)  completed 74  of the 282 removal actions,  more  than
twice the 31 completed in  FY  1987.  PRPs also undertook 108 of  the  328  removal
actions that were started.

     Of the 72 remedial action (RA) starts, PRPs financed 21;  they also financed
11 of the 31  RAs completed during the  year.   PRPs will finance  cleanup  for 50
of the 152 RODs that were signed,  and they started 30 of the 99 remedial designs
(RDs), which are increases over FY87 levels in both categories.

     The Agency  also made  progress in meeting the  statutory goals  for Remedial
Investigations/Feasibility Studies (RI/FS), and Remedial Actions  (RA).  By year-
end,  224 of the  required 275  RI/FS  new starts at NPL sites were underway,  and
RA contracts had been awarded  for 74 of  the  required 175 RA new starts.  (Exhibit
1.0-2 illustrates progress toward meeting the RI/FS and RA statutory goals.)

     The Superfund enforcement program met or exceeded most targets, resulting
in record-setting accomplishments.   By  the  end  of the  fiscal  year, EPA  had
negotiated more settlement  agreements with PRPs than in any prior year, bringing
the total settlement value  to more than one billion dollars since  the start of
the  program  in  1980.   The  FY88  total  includes  29  consent  decrees  worth
approximately  $270  million in RD/RA work  and  unilateral  settlement  orders at
seven sites  for RD/RA work worth approximately $50  million.    Fifty-six  cost
recovery referrals from the EPA Regio'ns  to Headquarters under section 107 seeking
more than $120 million, exceeded  the target of 49.   The Agency  also reached 36
cost recovery settlements with an approximate value of $20 million.

     The Agency  exceeded its  FY88 Superfund Comprehensive Accomplishments  Plan
(SCAP)  targets  for  both  PA  and  SI completions.   The PA total  of 2,884 PA
completions exceeded the target of 2,432 by 19 percent.   The SI  total of 1,237
completions exceeded the  target of 1,117 by 11 percent.  Five sites were deleted
from the NPL,  and the Agency proposed  for deletion nine  additional  sites.  Also
during the fiscal year, EPA proposed to  list 229 sites on the National Priorities
List (NPL),  bringing the total number of final  and proposed sites  to 1,175 at the
end of the fiscal year.

     Shortly  after the end of the  fiscal year,  the Agency  issued both  the
proposed revisions to the National Contingency Plan  (NCP) and the Hazard Ranking
System  (HRS).   The NCP is  the Agency's "blueprint"  for conducting  removal and
remedial actions under the Superfund program.  The HRS is the  Superfund  pre-
remedial tool used  to  identify sites warranting inclusion on the NPL.   Both of
these activities are specifically mandated by CERCLA.

     Continuing  implementation  of recent contract  initiatives  supported field
activities.    EPA  completed Alternative  Remedial  Contract  Strategy  (ARCS)
contract negotiations  in all  10 Regions and awarded contracts in Regions 2, 3,
and  5.    The   Agency  also   took  advantage of  two  new  Environmental  Services
Assistance Teams Contracts that support Superfund laboratory needs.  The

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    Exhibit 1.0-1
                 Fiscal 1988 Field Work Accomplishments
         REMOVAL ACTION

              Starts                                                   328
              Completions                                              282

         REMEDIAL ACTION

              Starts                                                    72
              Completions                                               24

         FINAL REMEDIAL ACTION COMPLETIONS*                             7
         * Completed actions for sites at which the Agency does not anticipate any need for future
           remedial action starts.

         SOURCES:     CERCLIS; Superfund Site Completions and Deletions from the National Priorities
                    List.  HSCD/OERR, October 25,  1988.
provision of management assistance in analytical services is expected to improve
and streamline  the  cleanup process.

     Exhibit 1.0-3  summarizes overall accomplishments  for FY88,  and Exhibit
1.0-4 compares  FY88 accomplishments with those  of  prior fiscal years.

     Resource needs continued  to  grow in FY88,  and resources were directed  to
activities where  they were most  needed.  The percentage of resources  directed
to the Regions  increased  to 67 percent of the total workyears  (1783 out of 2642
total workyears)  funded under  the program.   EPA prepared its last budget (for
FY91) under the current  authorization during the summer and fall of 1989.

     Development of an effective budgetary administrative and support system has
also been an important activity.   The  infrastructure needed to manage  a maturing
Superfund program is  now in place.  Its elements include:

     •   The CERCLIS  data base and the SCAP for annual site-specific
         and program-wide management and accounting of resources;

     •   Tracking of  policy and regulatory projects to meet statutory
         deadlines;

     •   A new  contract  operations office to review, assess, and
         provide support  and guidance to Superfund program contract
         managers;

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             Progress Toward Implementing Superfund:  Fiscal Year 1988
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            Progress Toward Implementing Superfund: Fiscal Year 1988

                               Exhibit 1.0-3
   Summary of Fiscal  1988 Superfund Program Activities
REMOVAL

     Completions                                          282
          Fund-financed                                 (208)
          PRP-financed                                   (74)
     Starts                                               328
          Fund-financed                                 (220)
          PRP-financed                                  (108)
     Expedited  Response Actions                            7
          Fund-financed                                    (7)
          PRP-financed                                     (0)

PRE-REMEDIAL

     CERCLIS Inventory-Sites Added                     2,442
     PAs  - Preliminary Assessments                     2,884
     Sis  - Site Inspections                            1,237
     NPL  - National Priorities List                    1,175
          (Program to date)
          Proposed sites for listing                    (229)
          Final sites listed                               (0)
          Sites proposed for deletion                      (9)
          Sites deleted                                    5
REMEDIAL

     Sites where  work was completed during FY88           7
     Sites with remedial activities in progress
          on September 30, 1988                          580
     RODs - Records of Decision Signed                  152
     RI/FSs --  Remedial Investigation/Feasibility
          Study Completions                              152
                Fund-financed                            (102)
                PRP-financed                              (50)
     RI/FSs - Starts                                     150
                Fund-financed                             (93)
                PRP-financed                              (57)
     RI/FSs in  progress on September 30,  1988           563
          (including 14 stand-alone FSs and
           9 stand-alone RIs)
     RDs  -  Remedial Design Completions                   76
                Fund-financed                             (55)
                PRP-financed                              (21)
     RDs  - Remedial Design Starts                          99
                Fund-financed                             (69)
                PRP-financed                              (30)

SOURCES:    Report  to Congress on Progress Toward Implementinn Superfund: Fiscal Year 1987,
          OERR, April 1989; CERCLIS; FY 1988 ROD Suianarv Report. HSCD/OERR,  March 1989;
          Superfund Completions and Deletions from the Rational Priorities List. HSCD/OERR,
          October 25,  1988.

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            Progress Toward Implementing Superfund:  Fiscal Year 1988

                              Exhibit 1.0-3
                               (continued)
   Summary of  Fiscal 1988 Superfund  Program  Activities
RAs - Remedial Action Completions                         31
          Fund-financed                                  (20)
          PRP-financed                                   (11)
RAs - Remedial Action Starts                              72
          Fund-financed                                  (51)
          PRP-financed                                   (21)
RAs in progress  on September 30, 1988                    132

ENFORCEMENT

     Negotiated  Settlements                              226
          Approximate Value           $470,000,000
     Consent Decrees  for RD/RA Work                       29
          Approximate Value           $270,000,000
       RI/FS Settlements                                  77
          Approximate Value           $ 85,000,000
       Removal Settlements                                94
          Approximate Value           $ 67,000,000
     Unilateral  Orders - issued                           14
          Approximate Value           $136,000,000
     Unilateral  Orders - settlements                       7
          Approximate Value           $ 50,000,000
     Cost Recovery Referrals from
       Regions to  Headquarters                            56
          Approximate Value           $120,000,000
     Cost Recovery Referrals to
       Department  of  Justice                              59
          Approximate Value           $ 27,000,000
     Administrative Cost Recovery
       Settlements                                        36
          Approximate Value           $ 20,000,000

SOURCES:    CERCLIS:  FY 1988 ROD Summary Report. HSCD/OERR, March 1989; The Superfund ProRres
          Report as of September 30.  1988. OSWER, December 29, 1988; OSHER Annual Report;
          Fiscal Year 1988, November  1988.

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     •   Alternative Remedial Contract Strategy contracts, mini-Emergency
         Response Cleanup Services contracts, and Technical Assistance Team
         contracts; and

     •   A document information management system.

     Removal Program Activities

     During FY88, the removal program surpassed  its FY87 record of 226 completed
removal actions  by  a wide margin.   The Agency completed  282  removal actions:
208 using fund resources,  and 74 funded by potential responsible parties (PRPs).
Sixty-four of the total actions completed were undertaken at sites listed on the
NPL.  In addition,  the Agency started a  record 328 removal actions, 108 of which
are being financed by  PRPs and 79  of which were started at sites  listed on the
NPL.

     The Agency  also completed the Removal Action Universe Study  in FY88.   EPA
plans to use the information gathered to modify the budget and planning process
to  better  meet  removal program needs.   The  Agency  also  issued  several  key
guidance documents needed to implement the removal program during FY88 that:

     •   Describe all  of the procedural and administrative requirements
         for removal actions;

     •   Clarify the SARA section  104(c) exemption from the statutory
         time and dollar limits on removal actions;

     •   Provide comprehensive cost  management procedures  for use by  EPA
         when conducting Fund-financed removals;

     •   Establish a new action level for response to  contamination of a
         drinking water supply; and

     •   Instruct On-Scene Coordinators (OSCs)  and administrative support
         staff in the  requirements for on-site  file management at removal
         sites.

Also, EPA began preparing guidance  on  several  other  important aspects  of the
removal program, including draft guidance on post-removal  site control.

     Remedial Program Activities

     EPA completed a greater total number of remedial program activities during
FY88 than in any other year of the Superfund program.  Work at the construction
end of the remedial process has steadily increased.  From the enactment of CERCLA
through September 30,  1988,  207 remedial  action projects had begun.  Moreover,
the  number   of  sites  at  which  remedial actions  have  been PRP-financed  has
increased from seven  in  FY85 to  21 in  FY88.   The  Agency also completed 31
remedial actions (RAs) in FY88,  of which 19 were first completions,  five were
subsequent,   and seven were  final  site completions.   In  addition,  the  Agency
started 72 RAs,  of which PRPs financed  21 and the Fund financed 51.

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     In addition to the  strides  that the Agency has made in  completing site
activities, at the  end of the year, remedial activity had begun  at 580 of the
797 sites  listed as  final sites on the NPL.  The Agency completed 76 remedial
designs (RDs),  of which 61 were first  and 15 were subsequent  completions.  The
Agency also started 99 RDs, of which PRPs financed 30 and the Fund financed 69.

     Ninety-five of the 152 RODs  signed in FY88 addressed source  control, with
68 RODs involving treatment technologies.  Of the RODs involving source control
treatment  technologies,  26  (34   percent)   involved  incineration  or  thermal
destruction, 18  (24  percent)  involved solidification or stabilization,  10 (13
percent)  involved  vacuum extraction,  and  the  remaining 22  involved  other
treatment  technologies.

     Thirty-nine of the RODs were ground-water remediation only,  four were source
control interim actions, and 14 were no-further action.  Forty-nine of the RODs
employed both source control and ground-water remedies.

     The   remedial  program  also  further  developed  the  RI/FS   Improvements
Initiative,  which was  begun  in  FY87.   The  goal of  the RI/FS  Improvements
Initiative is to  improve  the  schedule  and cost-efficiency of  the  RI/FS process
while also improving the  technical  quality  of RI/FS work.   The  Office of Solid
Waste and  Emergency Response  (OSWER)  issued detailed  guidance for implementing
short-term  steps in  the  Initiative  in April  1988.    OSWER also  established
workgroups to address  the more complex, long-term issues  and issued a interim
final guidance on them  in October  1988.

     From  its eight-year experience with the Superfund program,  EPA has learned
that remedial activities can become increasingly costly and time-consuming.  The
Agency, therefore, has  recently increased its efforts to streamline the stages
of the remedial  process.   In  FY88,  the Agency completed an RI/FS  Cost Study to
determine  the reasons  for RI/FS cost growth and  the  best  plan  for controlling
costs.  To address  the recommendations of the  cost study,  EPA  has implemented
the Alternative Remedial Contracts Strategy, which promotes continuity throughout
the  performance   of  remedial  work at  each  site.    Recommendations  also  are
addressed  by the RI/FS Improvements Initiative and several expert systems for
estimating the costs of remedial actions.

     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.  In FY88, the Agency met the statutory
goal of completing preliminary assessments (PAs) on all sites in CERCLIS at the
time CERCLA was  amended (October 17,  1986).   In order to accomplish this goal,
the Agency completed PAs  on almost  1,000  sites  during the first quarter of the
fiscal year. Over the  entire  fiscal year, EPA completed  2,884 PAs, bringing the
total  number of  PAs  completed by the  Superfund program  to  27,069.    As  of
September 30, 1988,  only 2,944 sites in the CERCLIS inventory still required PAs.
In addition,  EPA  conducted 1,237 site inspections (Sis) during  FY88.  This brings
the total number of Sis completed by the Superfund program to 9,022.

     The Agency  proposed  229 sites  to be listed  on  the NPL and  deleted five
sites, and published notice  of its intention to  delete  nine  additional sites.

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


Also, the Agency further developed and partially implemented  a  strategy,  begun
in FY87, to expedite the pre-remedial process.  The  strategy  has  resulted in a
restructuring of the program to provide EPA with enough information early in the
pre-remedial process  to decide expeditiously which  sites require  further  EPA
evaluation.  The PA has been  expanded in scope and involves more  site-specific
research.  The SI is now divided into two  steps:   (1) the screening SI;  and (2)
the  listing SI.   The Agency  is currently  conducting field tests  to  fine-tune
these changes in the pre-remedial program.

     Enforcement Program Activities

     FY88 continued  the  trend that was  begun in FY87 toward  the  increased use
of PRP  monies  to fund  clean-up  activities,  increasing  the  proportion of  PRP
dollars to total expenditures.  From the beginning of the Superfund program in
1980 through the end of FY88, EPA has reached settlements for  PRPs to  conduct
response activities worth over one billion dollars.  During FY88, EPA negotiated
a total of 226  settlements  with a total value of approximately $470 million,  the
most of any year since  the  start of  Superfund.  These negotiations resulted in
55 RD/RA  settlements with  an approximate  total  value of  $320  million.   This
includes 29 consent decrees  lodged worth  approximately  $270 million in  RD/RA
work; another 19 consent decrees signed by  PRPs  for RD/RA work are currently in
government concurrence, with  the value  of  response yet to be determined.   The
number  of  consent  decrees  lodged  represents a 300  percent  increase over  the
number  of decrees  lodged  in FY87.    In  addition,   EPA negotiated  77  RI/FS
settlements worth approximately $85  million, and 94  removal  settlements  worth
approximately $67 million.   These settlements  are for  first or subsequent starts,
or for takeovers of projects  that EPA has already begun.

     If EPA cannot  reach a  settlement at a site with a PRP, and if the site  poses
an immediate threat to human health and the environment,  the  Agency can use its
authority under section 106 of CERCLA to issue a unilateral administrative  order
against the PRP.  EPA issued 14 unilateral  orders  under  section  106 during FY88
with a  potential value of  $136 million.   Of the  14, seven resulted in  RD/RA
settlements worth approximately $50 million,  one case  was settled under a lodged
consent decree,  two were referred to the Department  of Justice, and the remainder
are awaiting PRP responses.

     In cases where PRPs do not perform the clean-up  work at  sites, EPA has the
authority under section 104 of CERCLA to initiate  response actions at  the site
without delaying to  ascertain the outcome of legal action, and  subsequently to
file suit against PRPs  under  section 107  of  CERCLA  to recover  Superfund  money
spent by the Agency at the site.   From the  inception  of  SARA  through the end of
calendar  year  1988,  EPA had reached  166 cost  recovery  settlements  with  an
estimated value  of  $139 million.   During  FY88 alone, EPA recovered a  total of
more  than $55.6  million  from PRPs  at 121 sites;   even greater numbers  of
settlements with larger dollar values  are  expected in FY89.    Cost  recovery
referrals under  section 107 exceeded the  target of 49;  56 cases  were  referred
from the EPA Regions to Headquarters, seeking over $120 million.

     Also, EPA issued two  guidance documents in FY88 related  to cost  recovery:
(1) The Superfund Cost Recovery Strategy, issued on  July 29, 1988, which provides
an overall framework for cost recovery actions;  and (2)  Guidance on Documenting
Decisions  Not   to  Take  Cost  Recovery Actions,  which  discusses  information

                                      10

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


necessary to document the basis  of EPA's decisions when recovery of unreimbursed
Superfund  monies is  not being  sought.    In addition,  on June  7,  1988,  EPA
delegated concurrence on most section 107 cost recovery actions to the  Regions,
providing  them  the  authority to take these  actions without prior Headquarters
approval.

     Major Rulemakings

     The Agency undertook a major effort to revise the NCP in fiscal  1988.   The
proposed revisions were published in the Federal Register on December 21,  1988,
and  reflect the  CERCLA section 105  requirement  that the NCP  be  revised  to
incorporate the new  statutory requirements  of SARA.   For the  remedial  program,
the proposed revisions incorporate a process to meet statutory clean-up standards
whereby remedial alternatives are evaluated against nine criteria, beginning with
the threshold criteria of overall protection of human health and the environment,
and  compliance  with federal and state  applicable or  relevant and appropriate
requirements (ARARs).

     The Agency  also completed  the  proposed revisions to  the  HRS during  FY88.
Proposed revisions were published in the Federal Register on December 23,  1988.
The proposal would add a number of new evaluation factors to the  scoring system
as required by  CERCLA section 105,  such as  the  threat that  site  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.   The revisions also would meet the  general mandate in section 105 that
the HRS, "to the  maximum extent feasible,"  accurately assess  the  relative risk
to human health  and the environment posed by potential  NPL sites.   The Agency
expects to finalize  the  rule in the second half  of fiscal  1989.

     In addition,  EPA developed two proposed rulemakings  adjusting  reportable
quantities  (RQs)  for specific CERCLA hazardous  substances.   The  first adjusts
RQs for 273 CERCLA hazardous substances, mostly carcinogens.  The second adjusts
RQs  for 757  radionuclides.   The Agency also published two proposed  rules  that
interpret   statutory  reporting  requirements.      One  proposes  the  Agency
interpretation of the reporting requirements for  continuous  releases under CERCLA
section 103(f)(2).    The  other explains  the  Agency's  interpretation of  the
exemptions under  CERCLA  section 101(10) for  federally permitted releases.

     Program Management Initiatives

     Completing the Superfund program management infrastructure was a significant
accomplishment this  fiscal  year.  The Agency has developed,  through  the use of
CERCLIS,  a  number   of  reports  that will   provide  a wide   range  of  program
performance  data for  management  personnel.   Reports can include  target  and
accomplishment  information  for  selected  SCAP  categories,, such  as  first  and
subsequent RI/FS  starts, RODs,  RDs, and  RAs.    Enforcement reporting  includes
RD/RA negotiations and settlements and cost recovery actions.  Senior management
reports also will   contain  progress,   duration,  and  cost analysis   of  RI/FS
projects,   and status of Regional resource or full-time equivalent utilization.

     In FY88,  the  Agency  also  made progress  in modifying  and updating  the
operational  status   of  CERCLIS.   The  updated  site-specific  data base  became
operational early in the  fiscal year and  is  being used by the Regions  to  track

                                      11

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


and store  information on  particular sites.   Overall,  each Region  enters an
average of 1,000  transactions  into  its  Regional data  base  each day.   WasteLAN
is a personal computer-based  version of  CERCLIS that  operates  as a local area
network data base.  WasteLAN became operational in Region 4 in FY88 and a trial
version of WasteLAN was made available to all the other Regions for evaluation.
Implementation is currently underway in Regions 2, 3,  and 5.

     CERCLA section  116  requires  the Agency  to  start RI/FSs for at  least 275
sites by October 1989 and  to  start RAs  for  at  least 175  additional sites by
October 1989,  with 200 more RA starts by October 1991.  The Office of Emergency
and Remedial Response is  using the enhanced capabilities  of  CERCLIS to track the
progress toward the satisfaction of the section 116  requirements.

     Contract Initiatives

     In order  to provide  for proactive management  of  the  Superfund contract
program, EPA  established the  Contract Operations Review and  Assessment Staff
(CORAS) in FY88.   The mission of  CORAS  is to assist OERR  in the management of
the  Superfund  program's  hazardous waste  clean-up  activities,  focusing  on
activities undertaken through contracts,  interagency agreements,  cooperative
agreements,  and  grants.   During  June  and July,   CORAS  conducted  several
assessments of the adequacy of contractor financial  reporting.

     In FY88,  EPA began implementation  of  the  Alternative Remedial Contract
Strategy (ARCS).   The ARCS program injects more  contractors  into the remedial
contracting pool,  providing incentive for  improved performance  and promoting
project continuity.  EPA awarded the first ARCS contracts in Regions  3 and 5 in
January 1988, and as of the end of FY88  had awarded  18 of the anticipated 45
contracts.

     Minority Firm  Participation in Superfund Contracting

     Total minority  contracting for FY88 was  $39  million.   The Agency employed
an  extensive program to   identify  additional  minority  firms  for  potential
opportunities as either Superfund  prime contractors  or subcontractors.   The
program included  the  following activities:

     •   Identification  of  qualified minority firms  through screening
         of the Minority Business Development Agency's Profile
         System;

     •   Conducting hazardous  waste clean-up  training programs  in
         four major  cities  nationwide;

     •   Sponsoring  a minority procurement conference  and minority
         business enterprise/women's business enterprise training
         workshops;  and

     •   Conducting  Congressional workshops on the Superfund
         procurement  progress  at the request  of several  U.S.
         Representatives.
                                       12

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


     Federal Facility Compliance with Superfund Requirements

     EPA  continued  to  focus  special  attention  on  improving  compliance  with
requirements under  CERCLA at federal  facilities.   The Agency negotiated  model
interagency compliance  agreements for site  remediation under CERCLA with both
the Department  of Defense and the Department  of Energy in the summer of  1988.
These  agencies  already  have  signed several  agreements  using  the  model,  and
negotiations are  underway  at  more  than  20  federal  facility sites  around  the
country.    The  Federal  Facilities  Task  Force,   established  in  FY87,   made
substantial  progress  in FY88,  including  publication of the  Federal Agency
Hazardous Waste Compliance  Docket.    This  docket  lists  over 1,000 facilities
targeted  for  preliminary   assessments   to  determine  the   need for   further
investigations  and  possible listing  on the  NPL.

     EPA Partnership with States and Indian Tribes

     Thirty-five  states  and Puerto  Rico  entered into core program  cooperative
agreements  (CPCAs)  with EPA  during FY88.    CPCAs  are negotiated  and funded
annually  to help  ensure  that each state or Indian tribe has  the  funds to  carry
out  CERCLA  activities.   OSWER  issued  final  Guidance  on State Core  Program
Cooperative Agreements on December 18, 1987.  Also during the fiscal year,  the
Agency, with  the help of the National Governors  Association,  completed  draft
guidance  to  assist  states  in meeting the  hazardous  waste  capacity assurance
requirements of CERCLA section 104(c)(9).

     The  Agency conducted three  Indian Outreach Workshops for Indian tribes  in
June  and  July  of  1988  covering  all  aspects  of  the  Superfund  program.    In
addition,  EPA  and the Navajo  nation began negotiating a number  of agreements
including a CPCA  supporting the  newly  established Navajo  Superfund Office.

     Public Participation

     EPA  awarded  four Technical Assistance Grants  (TAGs)  during fiscal  1988.
SARA  established the  TAG program,  which provides  up  to $50,000 to eligible
citizen groups,  to  obtain  assistance  in interpreting information  related  to
activities at NPL sites.

     From the time  of publication of  the TAG  interim final  rule  in March 1988
until February 3, 1989,  EPA Regional offices received 80  letters  from citizens'
groups  expressing  intent  to  apply  for  grants  and 13  draft or final  grant
applications.  Funds were first  made available for TAGs in FY88.

     Development of Treatment Technology

     EPA  announced  on  November  4,  1988,  the  selection  of  seven  emerging
technologies for funding under the Superfund Innovative Technologies Evaluation
(SITE) program.  The SITE program was established to promote  the  development and
use of alternative technologies to address hazardous waste problems at Superfund
sites.  The program, a joint effort between OSWER and the  Office  of Research and
Development   (ORD),   deals  with   technologies   for  recycling,   separation,
detoxification, destruction,  stabilization, and hauling  of hazardous chemical
wastes.   The  emerging SITE program provides  up to  $300,000  in funding  to  an
                                       13

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                 Progress Toward Implementing Super-fund:  Fiscal Year 1988


individual developer to assist  in taking a promising technology from  the  bench
to pilot stage.

     In addition  to  the emerging program,  the  demonstration program  addresses
technologies which are  further  developed.  These  technologies are at pilot  or
full scale and ready to be tested on Superfund waste.  There  are 29 projects  in
the program, and  during FY88, six technologies were demonstrated at  Superfund
sites across the country.  At least 11 demonstrations are currently planned for
fiscal 1989.
                                       14

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
2.0   INTRODUCTION

     2.1  Organization of the Report

     This Report  documents  progress  made by EPA  toward implementing Superfund
during 1988, with particular  emphasis on cleanup activities.   Accordingly,  it
is  organized so  that progress  made  in removal  and  remedial activities  is
presented before information concerning pre-remedial program activities, rather
than in the sequence  in which  it occurs chronologically.  Chapter 3.0 summarizes
the removal and remedial program FY88 accomplishments and describes the process
a site goes through during a removal  or a remedial action.  Chapter 4.0 presents
the accomplishments of the pre-remedial program and describes the site discovery
and  assessment  process.   Chapter  5.0  explains  the NPL  listing process  and
provides information on sites added to and deleted from the list.

     The Agency has  also focused on  increasing  the  role of PRPs  in Superfund
implementation during  the fiscal year.   Information  on the  enforcement program
and the progress the  program has made  in effecting potentially responsible party
cleanup of NPL sites comprises Chapter 6.0.   Chapter 7.0 details participation
of states and Indian Tribes in the Superfund process, and Chapter 8.0 describes
mechanisms  for  community participation  and  the dissemination of  Superfund
information.  Chapter  9.0 describes  the components  of  the  Agency's  management
infrastructure,  resource utilization,  and the major rulemakings undertaken during
the fiscal year.  Chapters 10.0 through 14.0 satisfy statutory requirements for
reports on minority firm participation, the development  of technologies, and the
resources required to  implement Superfund.

     For purposes of brevity and consistency, when the acronym 'CERCLA' is used
in  the  Report,  it   refers   to  the Comprehensive  Environmental   Response,
Compensation, and Liability Act of 1980, as amended, by  the Superfund Amendments
and  Reauthorization  Act  (SARA)  of  1986.   When  Rulemakings  or other Federal
Register publications are discussed  in the text, the  citations for them have not
been  included  in the  text.   Instead, all  FY88  Federal Register  publications
related to Superfund are listed in Appendix D.  The list includes citations for
each  entry.   In  addition,  all  references  used  in  preparing  the  Report  and
citations for each of  these references are included  in  Appendix  G.

     The sources for  the information in each exhibit in the  Report are included
in the exhibit.   The  primary source  for all of the data included in this Report
is the CERCLA Information System (CERCLIS).

     22  Statutory Requirements for the Report

     In addition to providing an overview of EPA  FY88 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)(l)(A)  to
         include a detailed summary of each  feasibility study,
         Appendix B contains an abstract of  each record of decision
         completed during FY88.
                                      15

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        Progress Toward Implementing Superfund:  Fiscal Year 1988
The status and estimated date of completion of each
feasibility study and remedial action, required by sections
301(h)(l)(B) and (F),  are summarized in section 3.3.  The
status of enforcement actions and a comparison of FY88
enforcement actions with those undertaken in previous years
is included in Chapters 3.0 and 6.0.  Appendix A contains
detailed information concerning the status and estimated
time of completion of each feasibility study and remedial
investigation.  The appendix also provides information
required by Section 301(h)(l)(C) concerning remedial actions
that will not meet previously published schedules.

The evaluation of newly developed technologies required by
section 301(h)(l)(D) is described in Chapter 11.

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
3.3.  Section 3.3 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 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 14.

Chapter 10 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.
                              16

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                 Progress Toward Implementing Super-fund:  Fiscal Year 1988


3.0  RESPONSES AT SITES WITH HAZARDOUS SUBSTANCE RELEASES

     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, pollutant, or contaminant that may present  an imminent
and substantial danger  to  public health, welfare,  or  the environment.

     Two different programs have been developed that  use Fund money to respond
to  releases  of  hazardous substances.   The  removal program uses  Fund money in
short-term responses to releases  or threats of releases  that pose  a  danger to
human health or  the  environment.   The remedial program,  which is divided  into
three separate phases -- the  pre-remedial  phase,  the remedial action phase,  and
the operation and maintenance phase -- uses Fund money to address non-emergency
situations and problems that  are too complex to be addressed by removal actions.

     3.1  Removal Actions

     Status Report on Removal Actions

     The removal program,  which is  authorized under CERCLA section  104(a),  was
created  to  provide  an  authority  to  respond  to   incidents  or sites  involving
releases or  threats  of releases of hazardous substances  that present a  danger
to human health or the  environment.   In fiscal 1988,  more  removal actions were
started  and  completed than in  any  previous fiscal year.   Prior  to  FY88,  the
record high for removal  action  completions  was 229  in FY84 and the  record high
for removal  action starts was  304  in FY87, as shown in  Exhibit 3.1-1.   There
were  282  removal actions  completed and 328 removal  actions started in FY88.
Removal  actions are  undertaken on a  continuous  basis  throughout the year.
Consequently, many removals that were completed in FY88 were started in previous
fiscal years, and many  FY88 starts  will be  completed  in future fiscal years.

     Of  the  removal  actions  started in the fiscal year,  220 were or  are being
financed with money from the Trust Fund; 53 are at sites  listed or proposed for
listing on the NPL.   208  of the removal actions completed in the fiscal year were
financed with Fund money; 46  at sites listed or proposed for listing on the NPL.
At  the  end of  the fiscal year,  there  were 318  removal  actions  in  progress.
Exhibit 3.1-2, lists, by state,  the  number of removals financed by Superfund and
by PRPs.  The Agency exceeded its  FY88 targets  for removal  action starts  in all
but two Regions (5 and 9) and  spent  less money than was obligated for conducting
removal actions during  the fiscal year  in  all Regions.

     PRPs initiated  108 (33  percent) of the 328  removal action starts for  the
fiscal year.  Of  the 108 PRP-lead starts,  26 were at sites  listed  or proposed
for listing  on  the NPL.   In  addition, PRPs oversaw and funded 74  (26 percent)
of  the 282 removal  actions that were completed in the fiscal year.   Of  the 74
PRP lead completions,  17 were  at sites listed or proposed for  listing on  the
NPL.

     Removals are generally short-term responses  intended to stabilize or clean
up releases.  Chemical spills or fires,  and illegal disposal of toxic materials
(midnight dumping),  are  examples of emergencies that  might warrant  a removal


                                       17

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              Progress Toward Implementing Superfund:  Fiscal Year 1988
  300
    (0
   *->
    ^
    (0
   **

   to
                                 Exhibit 3.1-1


                   Removal Action Starts by Fiscal Year
           ;;:;g;f::;| Fund-Financed
                (TOTAL- 1,277)




                PRP-Flnanced

                (TOTAL-37 5)
                         60
                   28
                                                         284
                  208
           129
                               •V:
                                  10
                        196
                                        62
                                                  175
                                               86
                                                     58
                                           220
                                                            60
                                                                  108
Fiscal Year  1980 1981  1982  1983  1984  1985  1986  1987  1988
 TOTAL
28
 61   139   270   282   233   304   328 1,652
   250
    o
    ys
    9


    I
    o
    o
                Removal Action Completions by Fiscal Year
                Fund-Financed

                (TOTAL- 1,101)



                PRP-Flnanced

                (TOTAL-213)
           108
                         66
                   18
            0  0
                 201
                                          208
                                    195
                       153
                              162
                                        28
                                              55
                                                     24
                                                           31
                                                                 74
Fiscal Year  1980  1981  1982 1983  1984  1985 1986  1987  1988
 TOTAL
18
67    108   229   208   176   226   282  1,314
SOURCES: CERCLIS; R>port to Conflr»«« en Progr»t» Toward Implementing Sup»rfund: Fiscal Y«ar 1987,


       OERR, April, 1988.
                                    18

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Progress Toward Implementing Superfund:  Fiscal Year 1988
                  Exhibit 3.1-2
                 Fiscal 1988
            Removals By State

Region
1






2




3






4








5






NOTES :




SOURCE:

State
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Total
New Jersey
New York
Puerto Rico
Virgin Islands
Total
Delaware
District of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Total
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Total
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Total
''Expedited response actions (ERAs) are removals
underway. Throughout the text of this Report,
removal actions started in FY88. The total of
ERAs. Seven ERAs were started in FY88. Thus,
starts for FY88. ( ) = Number of proposed and
CERCLIS .
Fund-
Starts
2
4
13
5
1
0
25(5)
16
21
0
0
37(8)
3
0
1
38
5
6
53 (15)
4
10
11
13
4
13
6
1
62 (11)
2
8
9
1
11
3
34(8)
conducted at
and PRP-Financed
Completions
2
2
13
6
1
0
24 (10)
10
14
0
0
24(5)
2
0
3
26
3
15
49(8)
3
8
8
11
4
14
6
1
55 (11)
3
6
9
0
9
5
32(5)
sites with remedial action
ERAs have been included in the total of
removals in
this exhibit does not include
321 + 7 = 328, the total number of removal
final NFL sites.


                      19

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Progress Toward Implementing Superfund:  Fiscal Year 1988

                   Exhibit 3.1-2
                 Fiscal 1988
             Removals By State
                   (continued)

Region
6





7




8






9








10




TOTAL
SOURCE:

State
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Total
Iowa
Kansas
Missouri
Nebraska
Total
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Total
American Samoa
Arizona
California
Commonwealth of Marianas
Guam
Hawaii
Nevada
Trust Territories
Total
Alaska
Idaho
Oregon
Washington
Total
ALL REGIONS
CERCLIS .
Fund- and
Starts
3
4
2
2
13
24 (10)
2
3
26
2
33(3)
6
4
0
1
3
6
20(5)
0
1
14
2
0
0
2
0
19(4)
2
6
3
3
14(3)
321 (72)

PRP-Financed
Completions
2
4
1
3
8
ISfSJ
3
3
21
1
28(5)
9
4
0
0
2
3
7«(
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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


action.  EPA conducts removal actions at a wide range of sites including inactive
waste sites  and  active manufacturing or waste disposal facilities.  The sites
where removal actions  are conducted may or may not be listed or proposed  for the
NPL.  Some  sites are placed  on the NPL after removal actions have been taken.
Specific  activities undertaken  during a response  might  include treatment,
excavation,  pumping,   incineration,  barrier  installation,  provision  of  an
alternate water supply, or temporary relocation of residents.

     The breakdown of  fund-financed removals by incident category has shown some
variation.  For example,  the percentage of removal actions conducted in response
to midnight dumping has remained fairly constant,  reaching a high of 27 percent
in 1987 and a low of 22 percent in both 1983  and  1986.   The percent of removals
conducted  at active production facilities has also  remained fairly constant,
fluctuating  between 6 and 8  percent.   The  percent of  removals conducted at
inactive waste management facilities has generally decreased over time.  In 1983,
42 percent  of  all  removal actions were conducted at inactive waste management
facilities.   In  1986, 16 percent of  all  removal actions  were  undertaken at
inactive waste management facilities, and in 1988, 18 percent of  fund-financed
removals were conducted at inactive waste management facilities.   The percentage
of removals conducted  at  inactive production facilities and in response to other
types  of  incidents  (i.e.,  transportation  related  incidents,   active  waste
management  facilities,  and  miscellaneous  incidents)  has  fluctuated  from 27
percent in  1983 to  17 percent  in 1987 to 28 percent in 1988.

     Because  the purpose of removal  actions  is  to respond to more  immediate
threats that require  short-term actions,  removals generally do  not deal with
long-term environmental problems like area-wide contamination of  ground water.
Section 104(a) of  CERCLA, however, emphasizes that removal actions  should be
consistent with longer-term remedial actions.   SARA, by amending  section 104(c)
of CERCLA,  also  increased the limits  on  removal actions  from  six months and
$1,000,000  to one year and $2,000,000.  Extensions may be  granted if continued
action is judged to be otherwise appropriate and consistent with planned remedial
action.

     3.1.1  Types of Removal Actions

     EPA has established  three categories of removal actions based on the urgency
of  the  situation.    Incidents  or  sites  requiring  immediate  attention  are
considered classic emergencies.  Sites  that require attention within six months
are classified as time-critical.  Sites where attention is  not required for at
least six months  are deemed non-time-critical.

     Emergencies  such as  fires and explosions  and  time-critical removals at NPL
sites and time-critical   removals  that do not fall  under  any  other  response
authority are the  removal program's  highest  priorities.   In a March 31, 1988,
guidance  memorandum,   the  Office  of  Solid  Waste  and   Emergency  Response
(OSWER) explained that Regions may have to defer non-time-critical removal actions
in order  to ensure that  sufficient funds remain  available to address classic
emergencies. OSWER emphasizes that non-time-critical removals should be financed
using remedial funds made  available through enforcement activities. The Regions
are  also  advised  to  encourage other  parties (i.e.,  PRPs, state, and local
governments) to conduct  removal actions.   Whenever  time permits, EPA attempts
to identify  PRPs and  have them implement  the removal  action.   If this  is not

                                      21

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


feasible prior to undertaking an action, or  if the PRP is unwilling to carry out
the action, EPA can conduct the removal and pursue  cost recovery at & later date.

     3.12  The Removal Action Process

     Once  EPA  receives  notification of a release that potentially  warrants a
removal action, the Agency conducts a removal preliminary assessment.  Based on
the results, the Agency  can choose to take  any of several actions.  It can decide
to perform an  emergency removal,  a time-critical removal,  a  non-time-critical
removal, or take no further action.  Alternatively,  if the  situation warrants,
it can refer the site to the remedial program,  the  state, or  the PRP.

     3.12.1  Emergency and Time-Critical Removals

     Because timely response is necessary to eliminate the  threat  posed by the
release, the normal methods of choosing the appropriate response action and of
informing  the   public  of  the  action  are  initially forgone  when  conducting
emergency  removals.  After the response is underway or  before  beginning a time-
critical  response,  however,   the  Agency  is required to  prepare  an  action
memorandum that outlines the authority under  which  the removal is being conducted
and that describes and justifies the action being taken.  The Agency also must
establish  an administrative  record that contains  the  documents that  form the
basis for  the selection  of the response action.

     3.1.2.2  Non-Time-Critical Removals

     When  the  Agency determines  that  a release  warrants a  non-time-critical
removal action,  the response  personnel conduct an  engineering  evaluation/cost
analysis (EE/CA), and the response alternatives  identified in the EE/CA are made
available  to the public  in the administrative record.  The action memorandum is
signed and the  removal action  is performed.

     When  a removal action  is completed,  the  On-Scene  Coordinator  (OSC)  is
required to submit a report on the response that  accurately records the situation
at the site as  it developed,  the actions taken at  the site during the response,
the resources  committed for  the response,  and  the problems  encountered while
undertaking the  response.  The Agency  may decide  during or after  the response
to further evaluate conditions at the site to determine whether  remedial action
is warranted.    Exhibit  3.1-3  illustrates  the  steps taken when conducting a
removal action.

     3.13  The Removal Actions Universe Study

     The Agency  completed a Removal Action Universe Study in  FY88.   The study
is an in-depth  review and analysis of historical  removal  action types,
duration,  and cost.  The study looks at 625 Fund-financed removal  actions that
were initiated  from FY85 through the second quarter of FY88,  and identifies
trends in  removal activities and obligations.   For  example, the study reveals
that most  removal actions cost less than $50,000  and take more  than 90 days to
complete.  The  study also shows that classic emergency removal  actions are
generally  less  expensive to conduct than time-critical or non-time-critical
removal actions.  EPA plans to use the  information  that it  gathered while
                                      22

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                Progress Toward Implementing Superfund: Fiscal Year 1988
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                                            23

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


conducting the study to modify the budget and planning process  to better meet
removal program needs.

     3.1.4  Removal Actions  Taken During Remedial Actions

     Expedited response actions  (ERAs)  are  removal actions conducted  at sites
where a remedial action is  already underway.   The Agency conducted  seven ERAs
in FY88.

     ERAs  differ from  normal removal  actions  in  that they  are directed  by
remedial project managers  and are performed by remedial contractors, saving time
and money that would otherwise be spent bringing  in removal contractors.  ERAs
also ensure that the removal action is consistent with the  remedial action that
is  already  in  progress.     Typical   activities  involved  in  an  ERA  are  the
installation  of drainage  controls and  the  maintenance of  alternative water
supplies.  As is the case  with all  removal actions,  ERAs must  contribute to the
efficient  performance  of  any remedial action performed at  the site,  to  the
maximum extent practicable.

     In  an ERA, as  in all  non-time-critical response  actions,  the  Remedial
Project Manager  (RPM)  provides adequate  opportunity  for  PRPs   to conduct  the
response.   RPMs  coordinate  notification of  PRPs with  Regional  enforcement
personnel.   At  that time,  if a  PRP search has  not  already been  conducted,  a
search is begun and notice letters  are issued.  At sites designated as PRP-lead,
the  Region may  consider  issuing  a  unilateral  administrative  order  or,  if
necessary,  referring  the case  to resolution  through  judicial  action.    If
settlement is reached  and PRPs agree to perform the necessary  activities,  the
response is no longer considered an ERA.

     3.1.5  Removal Action Guidance

     The  Emergency Response  Division (ERD)   issued  or began work  on several
guidance documents  during the fiscal year on important aspects  of the removal
program, including guidance  on:

     •    Superfund removal  procedures;

     •    The new exemptions  under SARA for statutory  limits  on
          removal actions;

     •    Removal cost  management;

     •    Temporary relocation of  people  in response  to removal
          actions;

     •    Engineering evaluation/cost analysis;

     •    Nationally significant or precedent-setting  removals  at
          non-NPL  sites;

     •    Lowering  the  action level  for  initiating removal actions
          at drinking water contamination sites;
                                       24

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     •    File management; and

     •    Post-removal  site control.

     3.1.5.1  Superfund Removal Procedures Revision #3

     In  February  of  1988,  the Emergency  Response  Division  (ERD)  published
Superfund Removal  Procedures,  Revision #3.   This manual  provides EPA response
officials with uniform,  Agency-wide guidance on removal  actions.   The purpose
is  to  describe  in  one  manual  all  of  the  procedural  and  administrative
requirements for removal actions.   As a result, the  guidance addresses a wide
array of topics.   It  includes NCP definitions  relevant to the program, removal
policies as determined by OERR, and step-by-step directions for preparation and
approval of documentation.

     3.1.5.2  Consistency Exemption from the Statutory Limits on Removal Actions

     EPA developed guidance  clarifying the SARA section  104(c)  exemption from
the statutory time and dollar limits on removal actions.   SARA section 104(c)
specifies that  the limits  may be exceeded where "continued response action is
otherwise appropriate and consistent  with  the remedial  action  to  be taken."
The guidance describes the following  four  situations in which  the  use of the
exemption is "appropriate:"   to avoid  a  foreseeable threat; to prevent further
migration of  contaminants; to  use  as an alternative to  land  disposal;  or to
comply  with the  off-site policy.   The guidance  also  defines an  action as
"consistent" if  it contributes in some positive way  to the remedial action to
be taken, or, at a minimum,  does not hinder or interfere with future remedial
actions.  Any request  to enact  the  "consistency" exemption should cite the new
exemption criterion, and document both how continued  action at the site will be
consistent  with the remedial  action to be taken  and why  continued action is
appropriate for the specific  site.   The  final  guidance was distributed in June
1989.

     3.1.53  Removal Cost Management Manual

     In April of 1988,  ERD published the .Removal Cost Management Manual.  This
document provides  comprehensive cost  management procedures for  use  by EPA at
removals authorized by  CERCLA.   The manual  is  to  be  used by  the On-Scene
Coordinator (OSC)  and  other on-scene personnel when performing cost management
activities at Superfund  removal sites.  It includes a discussion of the concept
and an approach to  cost management,  techniques  for cost projection and tracking,
techniques  for cost  control  and  monitoring  and  verification  of   contractor
charges, and techniques  for cost  recovery and  cost  documentation.

     3.1.5.4  Temporary Relocation in the Removal Program

     ERD, in  close consultation with  the Federal  Emergency  Management Agency
(FEMA) began preparing guidance defining the roles  and responsibilities of the
two  agencies  with respect to  relocation of  people  in  response to  a removal
action.  Executive Order 12580 delegated to FEMA the responsibility for carrying
out  the permanent and  temporary  relocations of  people  that  are  sometimes
necessary when conducting  cleanup of Superfund sites.  EPA, however, makes the
final decision on  whether  relocation is  necessary  in any  particular  instance.


                                       25

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


     3.1.5.5  Engineering Evaluation/Cost Analysis

     ERD issued  a  guidance outline on EE/CAs on March 30,  1988.   The EE/CA  is
similar to an RI/FS in that it  focuses'-on the analysis  of response alternatives.
EPA is currently revising the EE/CA guidance.  The Agency also  hopes to provide,
through the  EE/CA,  better documentation on the selection  of  specific removal
actions and a vehicle  for  improved public participation in removal actions.

     3.1.5.6  Nationally Significant or Precedent-Setting Removals at Non-NPL Sites

     EPA made substantial  progress towards completing guidance that identifies
certain  removals at  non-NPL  sites  as  nationally  significant  or  precedent-
setting.  When a removal action  is deemed nationally significant or precedent-
setting, the Regions  must  obtain Headquarter's approval before conducting the
action.    The  guidance   identifies   the  following  removals  as  nationally
significant  or precedent  setting:    (1)   removals  affecting  other  sovereign
nations  and  Indian lands;  (2)   removals  involving   pesticide contamination,
dioxin,  consumer products in consumer  use,  and asbestos;  and  (3)  removals
involving the statutory exclusions or limitations in CERCLA.

     3.1.5.7  Removal Action Levels at Drinking-Water Contamination Sites

     On April  19,  1988,  the Agency issued  interim  final  guidance recommending
a new  action level for response  to contamination of  a drinking water supply.
ERD based  the  new action  level  on the drinking water equivalent level  (DWEL)
established  by the Safe Drinking Water  Act,  and on  the  10"'' lifetime  excess
cancer risk level established  by the  Superfund program as  the minimum level  to
which  sites  containing carcinogenic contamination must be  remediated.    In the
guidance, the Agency also  recommends removal actions at sites  where the numeric
action level  is  not exceeded,  but where  site-specific factors present serious
health risks  to the public.   ERD  expects  to  issue  final  guidance concerning
removal  action levels  at  drinking water  contamination  sites in  1989,  after
revising the interim  guidance to reflect  the  Office of Drinking  Water's new
policy concerning rounding health advisory numbers.

     3.1J5.8  File Management

     In July of 1988,  ERD issued  guidance on file management entitled Model
Program for  Removal Site  File Management.   This guidance  instructs  OSCs and
administrative support staff in the requirements for on-site file management  at
removal  sites.    It  contains  a  kit  and  a  list of  contents  for  successful
establishment of permanent files.

     3.1.5.9  Post-Removal Site Control

     In July of 1988,  the Agency  also  issued a draft policy statement clarifying
its position on post-removal site  control.  Post-removal site  control refers  to
the activities  that must  be continued upon completion of  a removal  action  in
order  to ensure  the success of the action,  for example, relighting gas flares,
replacing  filters,  and collecting leachate.   The policy  statement emphasizes
that the removal program should not perform post-removal site control.  Instead,
OSCs should make provisions before initiating the action to ensure that any such
                                       26

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


site  control  will be  adequately  performed  by  either the  state  or  local
government, a  PRP, or,  in certain cases,  the remedial  program.

     Also, the FY88 update to The Superfund Emergency  Response Actions  Summary
(Volume III) is  scheduled  for publication and distribution in June  1989.   The
summary  will  provide  the   removal  location,  NPL  status,  threats present,
mitigative actions undertaken, and cost of the action for all removals completed
throughout the history  of the program.

     3.2   The Remedial Program

     During the  fiscal  year,  the Agency made greater progress in  implementing
the remedial program as a whole  than in any other  year of Superfund1s history.
Through the remedial  program,  EPA develops and implements  long-term solutions
for  the  nation's most hazardous  sites.    The  remedial  program's  success
demonstrates that  Superfund  is not only comprehensive,  but  also  effective.

     As shown  in Exhibit 3.2-1,  the  remedial stage  of the Superfund  process
encompasses a  number  of cleanup phases.  After  a  site has been listed on  the
National Priorities List (NPL),  an RI/FS is generally conducted.  Next, the lead
agency designs and implements the selected remedy in the remedial design (RD)
and remedial action  (RA) phases,  respectively.   After  the  cleanup is complete
and the site has  been deleted from the NPL, the site remedy may be monitored and
periodically  reviewed.    For  the purpose  of  highlighting the  environmental
results of the remedial program,  the description in this section of  the Report
first focuses on the  remedial phases that  involve field work and later describes
the investigatory phases of  the program.

     3.2.1  Remedial Action

     The Agency  completed 31  remedial actions  (RAs) in FY88, among them 19  (61
percent)  first completions,  5 (16 percent) subsequent completions,   and  7  (23
percent)  final completions.   Of the 31 RAs that  the  Agency completed,  20  (65
percent) were Fund-financed,  and  11 (35 percent) were  PRP-financed.

     The Agency started more RAs  in FY88 than in any other year of the Superfund
program,  as  shown in  Exhibit 3.2-2.    During FY88,  a  total of 72   first  and
subsequent remedial  actions  were started.  Of the total of  72  RA  starts  for
FY88, 51  (71 percent)  were Fund-financed, and PRPs  financed 21  (29  percent).
This fiscal year's level of  accomplishment represents  35 percent  of the  total
of 207 RA starts over the history of Superfund.

     32.1.1 The  Remedial Action Process

     The  RA  process, which  is  illustrated  in  Exhibit 3.2-3,  is the  actual
construction or implementation phase of  the clean-up alternative that  the Agency
has selected for a site.  After the remedial design (RD) is complete for  sites
at which EPA has the lead,  management of  the clean-up  action is  turned  over to
the U.S.  Army  Corps  of Engineers (COE),  which has  long-term experience with
major construction projects.  The COE,  in turn, solicits bids from contractors
to perform the RA work.  EPA Remedial Project Managers  (RPMs) provide oversight
during the RA.
                                      27

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            Progress Toward Implementing Superfund: Fiscal Year 1988
                               Exhibit 3.2-1
           The Remedial Stage of the Superfund Process
          Site Listed on the
     National Priorities List (NPL)
            Remedial Investigation
                 Feasibility Study
                      Proposed Plan
                       Record of Decision
                            Remedial Design
                              Remedial Action
                                   Close Out Report
                                     Site Completion
        Initiation of
        Operation
     and Maintenance
                                            Site Deleted
                                            from the NPL
                                        CERCLA Section 121(c)
                                                Review
SOURCE: D»v«lop«d for this R»port.
                                   28

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                  Progress Toward Implementing Superfund:  Fiscal Year 1988
                                       Exhibit 3.2-2
                                Historical Remedial Action Starts
                      12
                     Fund-Financed (Total- 140)
                                                              21
                                                PRP-Flnanced (Total* 67)
                      1980 1981  1982  1983 1984  1985 1986 1987 1988  TOTAL
Fund
PRP
TOTAL
(%)
0
0
0
(0)
0
0
0
(0)
9
0
9
(4)
9
2
11
(5)
16
9
25
(12)
8
7
15
(7)
12
9
21
(10)
35
19
54
(26)
51
21
72
(35)
140
67
207
(99)
                NOTE: Aeeom>MMi«iti .Down mr» tot«l« of llr.t >nd •ubitqiunt lotloni. Poro.nt.j.. totil !••• th.n 100 poroont
                   b«c«n« •< raMMt.
              SOURCES: CenCl«;RitT»w»r* Fltoal Y.at 1 «»7, OERR, Apr" !•««.
     State-lead RA  work  is  initiated  through  a  cooperative agreement  with the
Agency.   In order to  expedite  the RA,  EPA encourages  states to retain the same
architectural  or engineering  firm that  provided  services  for  the  remedial
investigation/feasibility  study  (RI/FS).   PRP-lead and  -financed RA  work is
initiated  through a  settlement  agreement  with  EPA.    Whenever  possible,  EPA
negotiates with PRPs  to undertake the expense of design and construction work.

     At  Fund-financed sites,  EPA funds  90 percent of the  cost of  constructing
the  selected remedy.   The  10 percent  cost share that EPA  leaves for  states is
intended to encourage  states to  be actively involved as  full  partners in the
remedy.   At sites where the state or a political  subdivision is responsible for
the  operation of the  facility, the  state must contribute at least 50 percent of
the  cost of remedy  construction.

     3.2.1.2  Completed Projects

     As  shown in Exhibit 3.2-4, during FY88, there were 24 site completions and
two  long-term response actions  (LTRAs)  , for a total of  26 completions and LTRAs.
                                         29

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               Progress Toward Implementing Superfund:  Fiscal Year 1988

                                  Exhibit 3.2-3
                       The Remedial Action Process
        RPM and Lead Party
        Prepare and Execute
      Construction Agreement
       After Completion of RD
                                    Contractor Completes
                                         Construction
                                                 Pre-flnal Construction
                                              Conference With Contractor
         Lead Party Conducts
        Procurement Activities
                                                 Pre-final Site Inspection
                                                    and Certification
             EPA Conducts
       Oversight and Monitoring
       of Construction to Ensure
    Compliance with Environmental
    and Contractual Requirements
                                       Final Inspection
                                                 Remedial Action
                                                  EPA Acceptance of
                                                  Completed Project
            After one year,
        State or PRP Assumes
        Responsibility for O&M
                                         Is Long-Term
                                      O&M Necessary?
                                                     Deletion of Site
                                                        From NPL
O&M Report
 NOTES: For Federal-lead RAt, the Construction Agreement It an lnt«rag«ncy Agreement with the Corpa of Engineers
      and a Superfund State Contract. For State-lead RAs, it I* a Cooperative Agreement with the State. For PRP-Lead
      RAs, it Is the EPA-lssued document of settlement.
SOURCE: Superfund Remedial Design and Remedial Action Guidance, OERR, June 1988.
                                       30

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Progress Toward Implementing Super-fund: Fiscal Year 1988

                  Exhibit 32-4
  Site Completions During Fiscal 1988
Activity/Site Name
Noticed for Deletion
Matthews Electroplating
New Castle Steel
Presque Isle
A.L. Taylor
Galloway Pits
Lee ' s Lane
Mowbray Engineering
Newport Dump
Toftdahl Drum
Completed Close Out Reports Awaiting
Publication of Deletion Notice
Cooper Road
Krysowaty Farm
New Castle Steel
Wade (ABM)
Big River Sand
Jibboom Junkyard
Long-Term Response Actions
Sylvester
Tar Creek
Completed Final Actions Awaiting
Completion of Close Out Reports
South Brunswick Landfill
Taylor Borough
Paramore Surplus
Triana
Charlevoix Municipal Well Field
Norman Poer Farm
Northern Engraving
Peterson Sand and Gravel
LaBounty
SOURCE: Superfund Site Completions and Deletions
October 25, 1988.
State

Virginia
Delaware
Pennsylvania
Kentucky
Tennessee
Kentucky
Kentucky
Kentucky
Washington

New Jersey
New Jersey
Delaware
Pennsylvania
Kansas
California

New Hampshire
Oklahoma

New Jersey
Pennsylvania
Florida
Alabama
Michigan
Indiana
Wisconsin
Illinois
Indiana
from the National Priorities List.

Region

3
3
3
4
4
4
4
4
10

2
2
3
3
7
9

1
6

2
3
4
4
5
5
5
7
7
HSCD/OERR,
                      31

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                Progress Toward Implementing Superfund: Fiscal Year 1988


In FY88, EPA  deleted  five  sites from the National  Priorities  List (NPL) (see
Exhibit 5.2-1).  Over the history of the Superfund program,  there have been 18
final deletions.

     In September  1988,  the Agency  issued a  draft guidance,  Procedures for
Completion and Deletion of National Priorities List Sites.  The guidance focuses
on the technical and procedural requirements for determining  site completion and
for deleting sites from the NPL.  The guidance does not address sites that are
removed from the NPL to be deferred to a clean-up authority other than CERCLA,
nor does it address completions at proposed NPL sites.

     According  to  the guidance,  following  implementation  of  all appropriate
remedial actions,  an NPL site  is  classified as  either a. completion or a long-
term  response  action (LTRA).   Both  completions and  LTRAs require  that all
activities identified in  the ROD for remedial sites or the  action memorandum for
removal sites be implemented and  performed  according to clean-up requirements
and design specifications.   All pathways of exposure must be addressed.

     Long-term response actions are  activities  that require continued on-site
activity for an indefinite period of time before the clean-up levels specified
in the ROD  or action memorandum are achieved for one or more pathway of exposure.
Site completion occurs at the point where clean-up levels are achieved, and no
further remedial activity is required or appropriate  at the site to  protect human
health or the environment.

     Protection can be provided through treatment,  containment or removal of
waste, provision of an alternate water supply,  or use of  institutional controls.
According to the Completion and Deletion  guidance,  it is not necessary that all
waste be treated or removed,  as long  as protection  is achieved.  Generally, the
methods of protection for a site will be determined in the ROD.

     In  cases  where  waste  has  been left  on  site,   the  review  procedures
established in section 121(c) of SARA (see section 3.2.1.4 below)  will continue
to be appropriate regardless of the completion or deletion  status of the site.
Following site completion,  it may still be necessary to perform some operation
and maintenance (O&M) activities to maintain the integrity  of the remedy.  O&M
must be performed by either the state or PRPs.

     EPA Headquarters and states have the opportunity to comment  on completion
decisions  through review of the Superfund Site  Close Out Report for the site.
The Close  Out Report represents  a modification made this  year to completion
policy.  The Close Out Report provides a brief, technical demonstration of how
the implemented remedy at the site satisfies the completion requirements.

     The exact  format and  contents of the report will  vary,  depending on the
site conditions, but the report should address the following components:

     •    Summary of site conditions;

     •    Demonstration of quality control for clean-up actions;

     •    Data that demonstrate achievement of cle.an-up levels;
                                      32

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     •    Summary of O&M;

     •    Data that demonstrate protectiveness; and

     •    A bibliography of site documents.

For Fund-lead and PRP-lead sites,  the Region prepares the Close Out Report,  and
the Regional Administrator  approves it.   For  state-lead sites,  the state  may
elect to prepare the report,  but the Regional Administrator's  approval  is  still
required.

     32.13  Site Operation and Maintenance

     Operation and Maintenance (O&M) is  the final phase in the  remedial  process.
A state  or a PRP  conducts  O&M activities  at  a site  after  a response action
occurs to ensure that the cleanup or containment system is functioning  properly
and to maintain  the  integrity of  completed remedial  actions.   O&M begins at  a
site after a remedy has been  completed.

     For Fund-financed  actions,  the Fund pays  90 percent of  the costs of  O&M
activities for the first year  after  an action is implemented,  and the  state pays
the remaining 10 percent.  This funding arrangement  is  intended  to ensure that
the remedy is put in place and functioning properly.   At sites where  a  state or
political  subdivision  was responsible  for  operation of  the facility,  EPA's
contribution to  the  cost of  O&M in  the first  year may be 50 percent  or  less.'
After the first year, however, all  O&M  costs are paid by the  state.

     SARA modified CERCLA section 104 to include new requirements for  sites with
Fund-financed remedial  actions  that involve  treatment or other  measures  to
restore contaminated ground  or surface water  quality to a level that  assures
protection  of  human health  and  the  environment.    The  operation  of  such
treatments for  a  period up  to 10 years after the construction or commencement
of operation is considered remedial action.  The Fund, therefore, pays  up  to 90
percent  of  the  costs  of the  treatment  for   a  period  of   up  to  10 years.
Activities required  to  maintain  the effectiveness of such treatment following
the 10-year period or after remedial action  is  complete,  whichever is  earlier,
are considered O&M.

     The Rl/FS report and the ROD indicate the  types  of O&M activities  required
for a site and  provide  estimates of their  costs.  O&M activities may  include
collection and  treatment of  ground water  or  leachate,  maintenance of water
monitoring units, and overall site  upkeep.  At  the completion of Fund-financed
O&M activities,  the state prepares and submits  an O&M Report to EPA.   The report
includes  a  description of  O&M  activities performed,   the  results  of  site
monitoring,  and  a description of any additional  activities  to be undertaken.
For PRP-funded O&M activities, the  O&M  Report may include additional elements.

     As more sites become eligible for monitoring, accomplishment data  for this
phase will be examined.   The Agency  plans to publish a guidance document on O&M.
                                      33

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     3.2.1.4  Sites to be Reviewed Under CERCLA Section 121(c)

     EPA carefully monitors  sites  over  the  long-term  to ensure  that their
remedies are  fully protective  of human health  and the  environment.   CERCLA
section 121(c)  directs  periodic review of sites  where remedial action leaves
hazardous substances, pollutants, or contaminants above health-based levels on
site.  According to  section  121(c),  the review must take place at least every
five years  after the initiation  of remedial action.   A  review  must  also be
conducted at  each site  where  a  substance  remains  on site  if  the standards
initially used  to  define protective levels are  subsequently  changed.   CERCLA
section  121(c)   requires  that  a  report be  sent to  Congress that  lists  the
facilities  for  which periodic  reviews  are required,  the results  of  all  the
reviews, and any action taken as a result of the reviews.

     The Agency  is presently  developing its  policy on the frequency and scope
of section  121(c)  review.  Even sites  that have been deleted from the NPL may
be reviewed.  The Agency is presently conducting a review to determine at which
of these deleted sites contaminants exceed health-based levels.  Exhibit 3.2-5
is a list of these potential  sites only.  In addition,  the Agency may decide to
review a small number of sites where remedial action has been  initiated and has
continued for at least five years, and where contaminants  remain on site above
health-based levels.   Thus, Exhibit  3.2-5 may  not be a definitive list of the
sites to be reviewed.   The Agency does  not plan to review non-NPL sites where
removal actions  have been  taken.   Contents of  site review will vary from site
to site, based  on  the complexity  of the problems at the site.  Work plans and
fact sheets for the review  guidance document were completed just after the close
of FY88.

     The Agency  has  identified  certain  procedures to be followed to carry out
the  review  provisions  of CERCLA  section 121(c) .    If  the  concentration of
contaminants  left  on a  site completed after   the  enactment  of  SARA  exceeds
established levels, OSWER proposes to conduct a review to ensure that the remedy
continues to be protective  of human health and the environment.  If the periodic
review shows that a site remedy  is no longer protective of human health and the
environment,  additional  action  to mitigate  the threat will  be evaluated and
taken.    This  approach  is consistent  with clean  closure under  the  Resource
Conservation  and Recovery Act  (RCRA).    Reviews will be conducted  at sites
currently considered  to  have  "safe" levels of contaminants if and when standards
defining protective levels are changed.   The  level of review will be determined
by the extent  to which  these  new standards  indicate that  these sites are then
considered to have consequently "unsafe" levels of  contamination.

     In FY89,  EPA  will  propose  a policy defining  the  sites  where the reviews
must be conducted and establishing the purpose of the  review.  The application
of this policy  will be  affected by  the  progress made  in  implementing remedies
that adhere to the clean-up standards specified in section 121 of CERCLA.  When
OSWER finalizes the policy  for implementing section 121(c), operating procedures
will be established  for  tracking,  re-examining,  and collecting information on
site status.  The policy will ensure that no site  at which hazardous substances
remain on site above  health-based levels will be deleted  from the NPL until at
least one review has  been conducted at it and the Agency has determined that the
remedy remains protective.  OSWER will also establish procedures for determining
the progress made  in reducing the number of facilities subject to review under

                                      34

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                Progress Toward Implementing Superfund:  Fiscal Year 1988
                                 Exhibit 32-5
    Potential Sites to  be Reviewed Under CERCLA Section 121(c)
                        as of September 30, 1988
Site Name
Sites Deleted Before the
Enactment of SARA
1. Chemical Metals
2. Chemical Minerals
3. Gratiot County Golf Course
4. Luminous Process
5 . Walcott Chemical
Sites Deleted After the
Enactment of SARA
1 . Enterprise Avenue
2 . Friedman Property
*3. Harris (Farley Street)
4. Lehigh Electric and Engineering
*5 . Middletown Road Dump
6 . Morris Arsenic Dump
*7 . Mountain View Mobile Homes
8. PCB Spills
9. PCB Warehouse
10. PCB Wastes
11 . Taputimu Farm
*12. Tri-City Oil Conservationist
*13. Varsol Spills
State Region


Maryland 3
Ohio 5
Michigan 5
Georgia 4
Mississippi 4


Pennsylvania 3
New Jersey 2
Texas 6
Pennsylvania 3
Maryland 3
Minnesota 5
Arizona 9
North Carolina 4
Mariana Islands 9
Pacific Islands 9
American Samoa 9
Florida 4
Florida 4
NOTES: * Deleted in FY88. The Agency is conducting a review to determine at which of these
sites contaminants exceed health-based levels. EPA plans to review sites at which
remedial action or operation and maintenance has
the final list of sites to be reviewed. A final
review is complete.
SOURCE: Superfund Site Completions and Deletions from the
started for possible inclusion on
list will be issued when this

National Prorities List.
HSCD/OERR, October 25, 1988.
section 121(c).   Progress in this area will be dependent  upon  an  increase  in
selection of source-control remedies that include  treatment.

      The proposed revised NCP addresses how EPA could use RODs  to  specify the
need for frequent or specific reviews of the remedy selected.  For example,  the
ROD might specify that the site be  reviewed when a certain technology unavailable
at the time that  the ROD was signed becomes  available.
                                     35

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


      3.2.2  Remedial Investigations/Feasibility Studies

      The  Agency and PRPs  completed 152 RI/FSs in FY88,  among them  112  (74
percent) first  completions  and 40 (26 percent)  subsequent  completions.   These
fiscal year  accomplishments are  illustrated in Exhibit  3.2-6.   EPA  and PRPs
started a  total  of 150  remedial  investigation/ feasibility  studies  (RI/FSs) in
the FY88.  Of the total  of 150  RI/FS  starts for FY88, 93 (62 percent) were Fund-
financed,  and PRPs  financed  57  (38 percent).   This  fiscal  year's  level of
accomplishment represents 16 percent of the  total  of 938  RI/FS starts over the
history of  Superfund.   Historical  RI/FS  starts  are   illustrated  in  Exhibit
3.2-7.

      In addition,  of  the  total of  152 RI/FS  completions  in FY88,  the Fund
financed 102 (67 percent), and PRPs  financed  50 (33 percent).  These RI/FS start
and completion accomplishments  reflect the Agency' s continued emphasis throughout
the history of  the  program to  initiate responses  that are  funded  by  PRPs,
whenever possible.

      Of the total of 150 RI/FS starts during FY88, 101 (67  percent) were first
starts, and  49  (33  percent) were subsequent starts.   An RI/FS  first  start is
the first  plan  initiated  for a site  to scope a permanent  solution to  the
containment  problem.   (For  a full description of operable  units and first and
subsequent starts, see  below).

      322.1 The  Remedial Investigation/Feasibility Study Process

      At the start of each remedial site cleanup, EPA conducts an  RI/FS to better
define problems  at  hazardous waste  sites that appear to present risks  and to
evaluate options for addressing those problems.  The RI/FS process is illustrated
in Exhibit 3.2-8.  The  Agency  considers the  RI and the FS to  be concurrent but
distinct  processes.    The  data  that  are collected  in the  RI  influence  the
development  of  appropriate  clean-up alternative approaches in  the  FS,  but the
RI and the FS are not  simply sequential phases  of  a single process.   Instead,
the  stages  of  the RI/FS   process  feed into  each  other  and  often  occur
simultaneously.   The RI/FS process  should be  tailored to match the  scope and
nature of  the problem  at each site.  Before the lead  agency  begins the RI/FS,
it  conducts  a  scoping  phase,  during  which  it  develops  work plans  and  other
project plans for the site,  including one for  community relations.

      The  RI is the process  of  defining the  nature  and extent  of the threat
presented  by the  contamination at  a  site,  and  it  includes   the  following
activities:

      •    Site  characterization, which is  the actual  field sampling and
           laboratory analyses of air,  ground water,  surface  water,
           soil, and contaminants;

      •    Baseline  risk  assessment,  which  is  the  determination of the
           magnitude of the threats that are or may be posed by site
           contaminants in  the absence of remedial action;  and
                                       36

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            Progress Toward Implementing Superl'und:  Fiscal Year 1988
                               Exhibit 3.2-6
           Superfund Remedial Investigation/Feasibility Study
          Starts and Completions During Fiscal 1988 by Region
   40
   30
u
   20
3
   10
-
-
-
-




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(TOTAL = 150)

Completions
(TOTAL = 152)





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                                  5     6
                                   Region
            8
9    10
                             Starts
Completions
Fund
PRP
TOTAL
93
57
150
102
50
152
SOURCE: CERCLIS.
                                 37

-------
              Progress Toward Implementing Superfund: Fiscal Year 1988
  200
  160   -
  120
.2.
"o"
"5

    80
    40   -
                                     Exhibit 3.2-7
                       Historical Remedial Investigation/
                              Feasibility Study Starts












PRP-Financed
(TOTAL = 260)


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Fund-Financed
(TOTAL = 678)
—
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              1981    1982   1983   1984   1985    1986    1987    1988   TOTAL
                                       Fiscal Year
TOTAL    21      35
    (%)    (2)      (4)
123    155    188     83
(13)    (17)    (20)     (9)
                                                               183    150     938
                                                               (20)    (16)   (101)
  NOTES: Accomplishment* shown are the turn of flrtt and aubt*qu»nt actloni; percentage* total mort than 100 percent
       because of rounding.
SOURCES: CERCLI8; Report to Cengr»i« on Pregreat Toward Implementing Suparfund: Flacal Y»ar 1987, OERR, April 1989.
                                       38

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             Progress Toward Implementing Superfund:  Fiscal Year 1988


                                Exhibit 3.2-8
        The Remedial Investigation/Feasibility Study Process
                          Preliminary Assessment,
                             Site Inspection, and
                                NPL Listing
                           SCOPE OF THE RI/FS
                 Site Planning
                                  Project Planning
                                              FEASIBILITY STUDY
REMEDIAL INVESTIGATION
                                                 Development
                                                of Alternatives
           Site Characterization
                                                  Screening
                                                of Alternatives
                                               Detailed Analysis
                                                of Alternatives
Treatablllty Investigations
                               Remedy Selection
                              Record of Decision
                              Remdlal Design, and
                                Remedial Action
SOURCE: Guldtno for Conducting B«m»dl«l lnv«»tlg«tlen« and Feasibility StudUi Und»r CERCLA. OERR. March 1988.
                                    39

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


     •    Treatability investigations, which are the bench, pilot,
          or full-scale tests of treatment technologies on samples
          of active site waste to determine their effectiveness,
          appropriateness, and key operating parameters.

     The FS serves as  the  mechanism for developing,  screening,  and analyzing  in
detail the universe of potential remedial alternatives.   Each alternative  is
evaluated with respect to the  following  nine  criteria,  which EPA developed  to
address the statutory requirements and goals of CERCLA section 121:

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

     (2)  Compliance   with   applicable   or   relevant   and   appropriate
          requirements (ARARs)  of state and  other  federal environmental
          laws;

     (3)  Long-term effectiveness and permanence;

     (4)  Toxicity, mobility,  or volume  reduction  achieved  through
          treatment;

     (5)  Short-term effectiveness;

     (6)  Implementability;

     (7)  Cost;

     (8)  State acceptance;  and

     (9)  Community acceptance.

     The first two are threshold  criteria  that  must be  satisfied in order for
a remedial alternative to be eligible for selection.   The  third through the
seventh criteria are primary balancing criteria that the Agency uses to weigh
major  trade-offs  among alternatives.    The  last  two  criteria  are modifying
criteria that the Agency considers after  formally receiving public comment.   It
is  by  balancing  trade-offs  with  respect to  these  factors  that  the Agency
identifies a  preferred remedy,  which is  presented for  public  comment  in  a
proposed plan.   These  factors also  form the  primary  basis  for the Ageny's
determination as  to which alternatives are cost-effective and which one uses
permanent solutions and treatment to the maximum extent practicable.

     Operable Units

     To handle complex site remediation problems efficiently, the Agency often
divides sites into several distinct stages, which it refers to  as operable units
(OUs).    Operable Units are  discrete  actions  that  comprise  incremental steps
toward the final remedy.   The  Agency may specify  OUs  according to location,
media,   or  the anticipated  duration  of  necessary  remedial  activities.   For
example, it  may  implement an  OU to prevent  further migration of  a plume  of
contaminants  in  ground water,   or  it  may  address  the contaminated  soil  or  a
lagoon that is the primary source of contaminants at a site.
                                      40

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


     The Agency  often designates OUs at a  site  at the start of or  during the
RI/FS,  but  it does not  always conduct the  remediation of each operable  unit
simultaneously.   After the Agency chooses "a remedy for an operable  unit,  the
remedial design phase  usually  follows  for  that particular  action,  and then the
Agency begins the construction of  the  remedial action.

     The Agency  refers to the  first OU  for which it obligates funds to begin
remedial work as the first start and  to the  obligation of funds for the OUs that
follow as subsequent  starts.

     Many events influence the progress of an OU through the Superfund process,
and  taking  the  OU  approach  to site  cleanup  enables  EPA  to effectively  set
priorities and to provide better overall project management by promoting rapid
risk reduction for  the most pressing remediation activities.

     3222  Streamlining the Remedial Investigation/Feasibility Study Process

     In  general,  over the course  of  Superfund,  the  costs  and durations  of
remedial activities have  increased.   EPA  has  accelerated  the  pace of  site
cleanups, but  there remains  Agency-wide concern about  finding ways  to further
accelerate the pace so that the burdens  on the Fund can be reduced.

     Remedial Investigation/Feasibility Study Cost Study

     During  FY88,  the Agency  completed  an  RI/FS  Cost  Study to determine  the
reasons for cost  growth  and to evaluate  plans  for controlling costs.   The two-
volume study  included the  following  qualitative  and quantitative  findings:

     •    Costs of  federal-lead sites  are  higher than costs at
          state-lead  sites;

     •    Costs vary  from  Region to  Region;

     •    Regional  cost  variation, however,  has  little  impact on
          project duration;

     •    Work plan costs  are  relatively constant, regardless of total
          project costs;

     •    PRP negotiations have significant impacts on RI/FS  costs;  and

     •    Changes in  RPM and  contractor  personnel can significantly
          increase  RI/FS costs.

     The cost study recommended that the average cost of an RI/FS be reduced to
$250,000 per operable unit.   One way  that these costs can  be lowered is  by
speeding up  sample  collection by doing more screening on site.   The conclusion
of  the  cost  study was that remedial project managers  (RPMs) need  better cost
estimation and project management tools.  Accordingly,  the Agency is developing
an  RI/FS Cost  Compendium,  which  it expects  to complete   in FY89.    The  Cost
Compendium will  serve RPMs as a reference  for evaluating  initial  project cost
and  level  of effort  (LOE)  estimates and  contractor proposals at  the scoping
phase of the RI/FS, in light  of historical cost  data.


                                       41

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     Key Management Initiatives

     The  recommendations  of  the  RI/FS Cost Study  are also  addressed by  the
implementation of the Alternative Remedial  Contracts Strategy (ARCS).   By  the
end of FY88, EPA completed  ARCS  negotiations for all Regions and awarded ARCS
contracts  in Regions  2,  3,  and  4.    In addition, the Agency awarded an ARCS
contract in the zone consisting of Regions 6, 7,  and 8.

     ARCS  is a major remedial project support  activity that was Introduced in
FY87.    (For a  full description  of  ARCS,  see  section  9.2  of  this  Report).
Central to ARCS is the concept of promoting  continuity of  remedial performance
from the  RI/FS  stage through construction  management.  The  strategy is also
designed  to  increase  the  level  of  competition  for  contract awards  and  the
involvement of states in the  clean-up process.

     Under ARCS,  EPA awards contracts in a two-step  process.   First,  the Agency
conducts negotiations with  a pool of firms  that  it has  selected as potential
ARCS contractors.  Then, it awards  contracts to several firms from within  the
pool.

     A second major  remedial project support activity that EPA introduced in
FY87 and further implemented in FY88 is the  RI/FS Improvements Initiative.   The
Agency expects the initiative to improve the pace, technical quality, and cost-
efficiency of the RI/FS process.  In April 1988,  the Agency  distributed  guidance
to the Regions that focuses  on the easily implemented, short-term goals of  the
initiative.  EPA also  established five workgroups to develop guidance for  the
more complex aspects of the  initiative, such as  program management, procurement,
funding,  and  technical  issues.     Regional  and  Headquarters   staff,  state
representatives,  and contractors participated in the workgroups,  and  a  steering
committee oversaw their progress.  The Agency expects to  issue guidance in FY89
on this  second phase  of initiatives, based  on  the  results of the workgroup's
efforts.

     Finally, EPA continued to develop the Cost of Remedial  Actions (CORA) Model
and the  Schedule for Cost  Estimating Expert System  (SCEES),  which have been
designed to assist the Regions in estimating remedial  costs.   The developments
focused  on ways  to make CORA and SCEES  easier  to use.    The Agency  plans to
release  SCEES  to the  Regions by the end of FY89.    The  systems provide  the
Regions  with historical cost  data  to supplement  their  own Superfund program
experience.    The Agency   established a  CORA  Hotline   in  FY88  to  provide
information and assistance  with the  system.

     3.2.23 Strategy to Meet the CERCLA Section 116 Targets

     By  the end of FY88, EPA had awarded  74  contracts  to perform RAs for  sites
on the 175 RA candidate list, or 42 percent of its CERCLA section 116  RA target.
The Agency had also begun  224 RI/FSs, or 81 percent of its CERCLA section  116
RI/FS target.  Accomplishments at sites on  the  175  RA  candidate  list are  shown
in Exhibit 3.2-9.   Progress toward  meeting the section  116 RI/FS  target is
illustrated in Exhibits 3.2-10.  Section  116 requires  the  Agency to:

     •     Start RI/FSs for  at least  275 sites by October 1989; arid
                                       42

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             Progress Toward Implementing Superfund: Fiscal Year 1988
  TOTAL
                                Exhibit 3.2-9
               Fiscal 1988 Accomplishments at Sites on the
                    175 Remedial Action Candidate List
                                              RA Contract Awarded
                                              In RD or RA Without
                                              Contract Award
                                                        9
10
                                                                TOTAL
8
6
3
17
3
22
9
34
13
12
9
34
9
11
11
31
17
10
8
35
9
7
4
20
3
1
3
7
5
4
2
11
6
0
4
10
1
2
3
6
74
75
56
205
                             Candidate  Cumualtive  RA Contracts
                                Site     RD Starts    Awarded
Fund
PRP
TOTAL
117
88
205
88
61
149
43
31
74
SOURCE CERCLIS.
                                  43

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           Progress Toward Implementing Superfund:  Fiscal Year 1988
                           Exhibit 3.2-10
           Progress Toward Meeting the 275 Remedial
            Investigation/Feasibility Study Start Target
   350
   300
£  250
tn
"o
3
   200
    150
    100
           RI/FS Study Target = 275
           (Deadline for Completion: 10/17/89)
; RI/FS Starts =2 24
    of         "
                  FY88 Quarters
                             FY89 Quarters
           RI/FS Starts
          (as of 9/30/88)
               Fund: 129
               PRP:    95
TOTAL:   224
  SOURCE: CERCUS.
                                44

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


     •    Start RAs for at  least  175  additional sites by October
          1989, and an additional 200 by October 1991.

     OSWER's strategy to meet  the 175 RA target stresses the need to establish
realistic  schedules,  meet  established  schedules,  and  set priorities  among
projects.   Superfund decisionmaking  must  often proceed  in the face  of many
scientific  unknowns  to meet   the  remedial  schedules.    In  spite  of  these
uncertainties,  the program is making a  concerted  effort  to  meet  statutory
schedules and to comply with the  goals they reflect.

     322.4  Remedial  Investigation/Feasibility Study Guidance

     In  October 1988,  EPA issued an interim  final  Guidance  for  Conducting
Remedial Investigations and Feasibility  Studies under CERCLA.   (The Agency had
issued an interim draft guidance for use  in March 1988.)  The guidance describes
the  general  process   for   conducting  an  RI/FS  and   provides  an  overall
understanding of the  role  of  the  RI/FS  in relation  to  other remedial process
components.  It also incorporates  the  key management initiatives that the Agency
has designed to streamline  the RI/FS  process.

     EPA plans to issue the final guidance documents  in FY89 that will describe
procedures  for  PRP participation in  the  RI/FS process  and the policy  to be
followed by RPMs to properly initiate, control,  and monitor PRP participation.

     323  Status Report on Remedial Investigations, Feasibility Studies, and Remedial Actions

     Under CERCLA sections  301(h)(l)(B) and (F) ,  EPA must report to Congress the
status and estimated completion date of each RI, FS, and RA project in progress
at the  end  of FY88.   Section 301(h)(l)(C)  requires  EPA to  provide  notice of
RI/FSs that will not meet a previously published schedule for completion and to
estimate new dates  of  completion.   On  September  30, 1988,  695 such projects were
in progress at 580 sites.   Among these 695 ongoing projects were 540 RI/FSs, 14
stand-alone FSs, 9 stand-alone RIs, and  132 RAs.  These projects are listed in
Appendix A.

     The status of the ongoing projects  is summarized in Exhibit 3.2-11,  based
on a comparison  of each project's planned completion date at  the end  of FY87
(where available),  with its planned completion date at the end of FY88.  Of the
695 projects ongoing at the end of FY88,  29 were on schedule, and 16 were ahead
of schedule.  Projects begun in the fiscal year (i.e., "new projects underway")
accounted  for 320  of  the  ongoing projects,  and  325  projects were  behind
schedule.   There  were also five  projects  that  were  begun  in  previous  fiscal
years that had no previous  estimates of completion.  These ongoing projects are
summarized in Exhibit 3.2-12 according to  their distribution by EPA Region and
state.

     3.2.4  Remedy Selection

     During FY88, the Agency signed a  total of  152  Records of Decision (RODs),
compared  to the  75 RODs  that the  Agency  signed in  FY87.    Exhibit  3.2-13
illustrates historical  RODs.    Of  the 152  RODs signed  during FY88, 102  (67
percent) were Fund-lead, and PRPs lead 50 (33 percent).   The ROD is  issued by
the lerd agency as the final remedial  action decision document.  As  such, the


                                       45

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                         Exhibit 3.2-11
                     Status of Ongoing RI/FS and RA Projects
                               at the End  of Fiscal 1988
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RI/FS


239

(563 In progress)

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•:•:•:•:•:•: RA (132 In progress)






154

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-------
             Progress Toward Implementing Superfund:  Fiscal Year 1988
                             Exhibit 32-12
Distribution of Ongoing Remedial Investigation,  Feasibility  Study,
           And Remedial Action Projects at the  End of
                 Fiscal 1988 by Region and State
Region
1






2



3





4








5






State
Connecticut
Massachusetts
Maine
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
Total
RI/FSs
3
17
5
6
5
1
37
48
43
6
97
1
2
43
11
0
63
5
17
2
3
1
9
6
6
49
15
14
50
11
19
22
133
RIs
0
0
0
1
0
0
1
0
1
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
FSs
0
1
0
2
0
0
3
2
0
0
2
0
0
0
0
0
0
0
1
0
0
0
0
0
0
1
0
0
0
1
0
0
1
RAs
3
2
1
0
2
0
8
12
15
0
27
1
1
13
1
2
18
3
6
0
2
0
0
1
0
12
1
4
6
14
2
3
30
Sites
4
14
6
8
6
1
39
56
48
6
no
8
3
50
12
2
75
6
23
2
5
1
9
7
6
59
16
17
51
20
21
24
149
                                 47

-------
             Progress Toward Implementing Super-fund:  Fiscal Year 1988
                             Exhibit 32-12
                              (continued)
Distribution  of  Ongoing Remedial Investigation, Feasibility Study,
           and  Remedial Action Projects at the End of
                 Fiscal 1988 by Region and State
Region
6




7



8



9

10

TOTAL ALL
NOTE:
SOURCE:
State
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Total
Iowa
Kansas
Missouri
Nebraska
Total
Colorado
Montana
Utah
Wyoming
Total
Arizona
California
Total
Idaho
Oregon
Washington
Total
REGIONS
States and territories
CERCLIS .
RI/FSs
4
0
2
2
6
.74
6
5
8
5
24
7
17
11
1
36
8
64
72
4
3
10
77
540
RIs
0
0
0
0
0
0
0
0
0
1
1
3
2
0
0
5
0
1
7
0
0
0
0
9
with no ongoing projects are


FSs
1
0
0
0
0
i
0
0
i
0
i
2
3
0
0
5
0
0
0
0
0
0
0
14
not included

RAs
2
3
0
0
6
11
2
0
6
0
5
7
0
0
0
7
0
8

-------
                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                     Exhibit 3.2-13
                        Historical Records of Decision Signed
            175
            150
            125
        V)
         M  100
        Q
        O
        DC
         O
         .Q
         E
         3
             75
             50
             25
                             PRP-Flnanced
                             Fund-Financed
                         I" '•-g-fr:::!
                    1981  1982  1983  1984  1985  1986  1987  1988
                                       Fiscal Year
                                                                    TOTAL
Fund
PRP
TOTAL
0
0
0
4
0
4
13
0
13
35
3
38
65
3
68
62
22
84
44
31
75
102
50
152
325
109
434
          NOTE: Accomplishment* shown »r» tho tottls of first and subioquont action*.
        SOURCES: Bopert to Congroti en Progf*** Towtrd Implomontlnq Suporfund Fl«c«l Yo«r 1*87, OERR, April 1«8»;
              FY 1»6« ROD Summary Roport, H8CD/OERR, Morch 1*8*.
number  of RODs  signed  is  an indicator  that  site remediation  is  progressing
smoothly  through  the  planning  stages.    This  fiscal  year's  total  level  of
accomplishment of 152 RODs signed represents 35 percent of the total  of 434  RODs
signed  over  the history  of Superfund.

     Of the  152 RODs  signed, 112  (74 percent) were RODs for first operable units,
and 40  RODs  (26 percent)  were for subsequent operable units,  as illustrated  in
Exhibit 3.2-14.

     The  selection   of  a  Superfund  remedial  course   of action  is  a two-step
process.   According to  the  remedy  selection  process,  the  lead  agency,  in
conjunction  with  the support agency,  reviews  the RI/FS  report to  identify  a
preferred alternative.  The  lead agency should be  alert  to new information  that
suggests  that changes  to the  selected remedy may  be  necessary  or  appropriate.
The preferred alternative is presented to  the public  in a proposed plan, along
                                         49

-------
            Progress Toward Implementing Superfund:  Fiscal Year 1988
    30
    20
  w
  Q
  O
  OC
  O
  <5
  |
  z
     10
                               Exhibit 3.2-14
                Records of Decision Signed in Fiscal 1988
                 for First and Subsequent Operable Units
                                                    Subsequent
                                                    Operable Units

                                                    First Operable
                                                    Units
                                   5    6
                                   Region
8
9
10
                                                                TOTAL
First
Subsequent
TOTAL
8
3
11
15
7
22
18
7
25
11
1
12
21
4
25
13
8
21
9
3
12
3
1
4
8
5
13
6
1
7
112
40
152
SOURCE: CERCLI8.
                                  50

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


with supporting  observations  and tentative analysis, for review and comment.
The remedy selection process is illustrated in Exhibit 3.2-15.

     The proposed plan is a key decision document,  and notice and comment  on that
plan is  required by the provisions of  CERCLA section 117.   The proposed plan
states clearly that the lead agency has identified a preferred alternative but
has not  made  a final decision on  which remedy to implement.   Changes  to the
preferred alternative  or a change  from the preferred alternative  to  another
alternative may  be  made,  if public comments or  additional data indicate that
these modifications would enable a remedy to better meet overall clean-up goals.

     The lead  agency reviews the  public  comments, consults  with  the  support
agency, ensures that the use of the preferred alternative remains appropriate,
and makes a decision.   The selected remedy is based  on  the evaluation of the
nine criteria developed to  address  the  goals and requirements  of CERCLA  section
121.

     The ROD  identifies and  describes the selected  remedy.   The ROD is  an
official, legal document that demonstrates  that  the  remedial action selection
process was  carried out  in accordance with statutory and regulatory requirements
of CERCLA section 121.  It serves as the centerpiece of  the administrative record
that a court will review in judging the appropriateness of EPA's decisions about
a site.  (For a full description of the administrative  record,  see section 9.5.2
of this Report).

     Because the  ROD  also  has  an  important  technical  role, it  contains  an
accurate, clear,   and complete summary  of  the problems posed by a site  and the
alternative ways  of addressing them, and the rationale behind the selection of
the remedy.   The ROD consists of the following three major parts:

     •    An authorized declaration describing the remedy selected;

     •    A decision summary that describes the site problems and
          threats posed, alternatives considered and their relative
          advantages and disadvantages, and the rationale for the
          remedy  selection; and

     •    A responsiveness summary describing and responding to
          public comments submitted on the proposed plan and RI/FS.

     Summary of Remedies Selected in Fiscal 1988

     Although each site in need of remedial action has unique characteristics,
the remedies selected  to  address  hazardous waste  problems  can be categorized
into a few  groups.   The remedies  selected in the  RODs that the Agency signed
during FY88 are summarized in Exhibit 3.2-16.

     One hundred  fifty-two  RODs were signed in FY88 to  address  the various types
of sources of contamination that may be present  at Superfund sites.  Ninety-five
of  the remedies  address  source  control, with   68 RODs  employing  treatment
technologies.   Of the RODs  involving source control treatment technologies,  26
(34 percent)   involve  incineration or  thermal destruction,  18  (24  percent)
involve solidification or stabilization, 10 (13 percent)  involve vacuum

                                      51

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              Progress Toward Implementing Superfund: Fiscal Year 1988


                                Exhibit 3.2-15
                    The Remedy Selection Process
       Prepare Proposed Plan
                                  Prepare ROD for Signature
      Receive Concurrence on
           Proposed Plan
                                  Receive Concurrence from
                                      Support Agency
                                          Brief AA of Support Agency
Prepare Draft ROD
                                           Submit ROD for Signature
Brief Lead Agency
Mangement on ROD
          Submit ROD to
         Program Offices
                                        ROD Signed
                                         Publish Notice and Make ROD
                                              Available to Public
 Submit ROD to
 Support Agency
SOURCE: CompiUd for this Report from Guldanc* on Preparing Sup«rfund D»cltlon
      Docum»nti: Th> Propo«>d Plan and th« Record of D>cl»lon, March 1988 Draft.
                                     52

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            Progress Toward Implementing Superfund: Fiscal Year 1988
                               Exhibit 32-16
   Summary of  Remedy Selection in  Records  of Decision
                        Signed  in Fiscal 1988
Remedy                                                   Total

Source Control Remediation

     Incineration/Thermal
       Destruction                                        26

     Solidification/Stabilization                       18

     Vacuum Extraction                                   10

     Volatilization/Soil Aeration                        6

     Soil Washing/Flushing                                6

     Biodegradation/Land Application                     6

     Other Treatment Technologies                     	4

         Subtotal                                            76

Containment Only Remediation

     On-Site Landfill Disposal                           24
     Off-Site Disposal                                 	3

         Subtotal                                            27

Non-Source Control Remediation

     Pump and Treatment                                  78
     Alternate Water Supply                              13
     Other                                                 5
     Leachate Treatment                                	3

         Subtotal                                            99

     TOTAL                                              202

NOTES:    More  than one remedy may be  associated with a site.  No further action RODs are not
         included in this summary. Vacuum extraction total includes the amended ROD that
         replaced the 12/21/84 ROD for Tyson's Dump, Pennsylvania.
SOURCE:    FY 1988 ROD Summary Report.  HSCD/OERR, March 1989.
                                    53

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


extraction, and the remaining 22 involve other treatment technologies.  Forty-
nine RODs  addressed both  source  control and ground-water remediation.  Of the
152 RODs signed in FY88, 95 were final source control RODs,  39 were ground-water
action  only  RODs,  4 were source control  interim action RODs,  and  14 were no
further action RODs.

     An 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 Hazard Ranking System (HRS)  score  for the site indicated
that a site response was warranted.  There may be several possible reasons for
such an outcome.   The HRS,  which is a  general  screening tool, uses a limited
data set,  but an RI/FS collects  and generates much more data,  since RI/FSs more
completely characterize the  threat.   Alternatively,  a previous removal action
at  the site,  or  the  completion  of  a previous  operable  unit,   or  natural
attenuation  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.   Exhibit 3.3-17 illustrates remedies  selected in historical
RODs.   The use  of treatment-based  source control remedies has been increasing
steadily over the history of the Superfund  program,  and the use of containment-
based source control remedies has been declining.

     Section 301(h)(l)(A) requires  that summaries of each FS  conducted during
the fiscal year be submitted  to Congress annually.  Since  the RODs summarize the
most  important  portions of  the  FSs,  summaries  for  this report, as  shown in
Appendix B,  are based on RODs that the Agency  signed during FY88  and include
information  on  the  major contaminants  of  concern  at  a site, the  remedial
alternatives considered, and the selected  remedy.

     Remedy  Selection Guidance Documents

     In March 1988, EPA issued a Draft Guidance on Preparing Superfund Decision
Documents: The Proposed Plan and Record of Decision  to assist  Regional, state,
and  Headquarters personnel  in  documenting  remedy  selection  decisions.   The
revised ROD guidance reflects the Agency's  six years of program experience since
the  original  guidance was issued.   It  also  reflects the enhanced partnership
between EPA  and states in the preparation of decision documents, as  specified
in CERCLA  section  121(f)(l).

     The guidance  includes  a discussion of the  following elements  of a remedy
selection:

     •     Developing  the proposed plan;

     •     Writing  the  proposed plan;

     •     Newspaper notification and public  comment  period
           provisions;
                                       54

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  Exhibit 3.2-17
         Remedies Selected in Historical Records of  Decision

Fiscal Year
1988
1987
1986
1985
1982-1984
SOURCES : Report
April
Treatment-Based
Source Control
Remedies
74%
57%
45%
23%
16%
to Congress on Progress Toward Implementing
1989: FY 1988 ROD Summary Report, HSCD/OERR.

Containment-Based
Source Control
Remedies
26%
43%
55%
77%
84%
Superfund: Fiscal Year 1987, OERR,
March 1989.
     •    Making significant changes to the proposed plan;

     •    Developing the ROD;

     •    Writing the ROD; and

     •    Making significant changes after the ROD is signed.

The  draft guidance  document was  circulated for  Regional comments  prior to
developing the final guidance.  The Agency issued interim final guidance  in June
1989.   The  Agency  added  to its  latest  guidance a  chapter  outlining  special
documentation procedures for no action, limited action, and contingency remedy
decisions.

     The ROD interim guidance and the forthcoming RI/FS final  guidance will be
used as interrelated,  interdependent documents.  EPA is also currently preparing
guidance on the role of federal facilities in the remedy selection process.

     Applicable or Relevant and Appropriate  Requirements

     EPA issued the draft CERCLA Compliance with Other Laws Manual Part I, for
use  in August  1988.   Part  II of  the Manual  is currently  being developed,
including a chapter addressing  "CERCLA Compliance with State Requirements."  The
two-part Manual provides  guidance  to Remedial Project Managers (RPMs) and On-
Scene Coordinators (OSCs)  on how to implement remedies  that comply with  federal
and State environmental requirements that are determined to be ARARs.  The State
Compliance  chapter  contains  quick-reference  charts   for identifying  state
                                      55

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


requirements that are potential ARARs and for determining whether they are ARARs
for a site.

     Part  I,  completed  in  June  1988,  addresses   general  procedures  for
determining ARARs and CERCLA compliance with  ARARs in  the Resource Conservation
and Recovery Act (RCRA), the Clean Water Act  (CWA),  the Safe Drinking Water Act
(SDWA),  and ground-water protection policies.  Part II  addresses compliance with
ARARs in the Clean Air Act  (CAA),   the Toxic  Substances  Control Act  (TSCA),  the
Surface Mining Control and Reclamation Act (SMCRA), and several other resource
protection statutes.

     32.5  Remedial Design

     The Agency  completed 76 RDs  during the  fiscal  year, among  them 61  (80
percent) first completions and 15  (20 percent) subsequent  completions.   Of the
RDs completed during the fiscal  year,  55 (72  percent)  were  Fund-financed and 21
(28 percent) were  PRP-financed.   There were  more remedial design  (RD)  starts
during  FY88  than  in any  other fiscal  year.  The historical  accomplishments,
including  this  fiscal year's record high, are  illustrated in Exhibit  3.2-18.
Of the  99  RDs that the Agency started during FY88, 69  (70 percent)  were  Fund-
financed,  and  PRPs  financed  the  remaining  30  (30 percent).   Sixty-five  (66
percent) were first starts,  and 34 (34 percent)  were subsequent starts.   The
FY88 level of accomplishment represents  32 percent of the total of 309 RD starts
over the history of  Superfund.

     32.5.1  The Remedial Design Process

     The purpose of  the RD phase of the cleanup process is to  design and draft
engineering plans  and specifications  for  the remedy selected.  The  RD  process
is illustrated  in  Exhibit 3.2-19.   Remedial  design projects  may appear  to be
similar  to any  other  major  construction project, but  the likely presence of
dangerous materials  demands special planning.

     The implementation of RD and subsequent RA activities flows from the remedy
selected in the ROD and cannot be  inconsistent with, or substantively different
from, the  remedy and its  intent.  In  addition, the RD  and the RA must meet all
necessary  federal and  state ARARs  identified  for  the  site.

     33  Response Action Work Force

     EPA has  placed  an  increasing emphasis  on  improving the efficiency  and
effectiveness of the  Superfund work force.

     An  October   1987  General  Accounting   Office   (GAO)   report  made   16
recommendations to Congress on how to  improve work force retention,  management,
and training.   In  response  to the report, the  Agency focused on the need for
experienced, knowledgeable  On-Scene  Coordinators  (OSCs)  and Remedial  Project
Managers  (RPMs).     OSCs  and RPMs represent  about  one-fourth  of  the  total
Superfund  work  force.   Although about half of Superfund employees  have worked
with the program for two to  five years, most OSCs and RPMs do  not have extensive
program experience.
                                       56

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   Exhibit 3.2-18
                         Historical Remedial Design Starts
        100
         75
      w
      **
      o
      o
      a
      <*•
      o
      |  50
      |
      z
         25
                         PRP-Financed
                         Fund-Financed
                                    £:,
                1980  1981 1982 1983  1984  1985  1986  1987 1988
                                     Fiscal Year
                                                                   TOTAL
Fund
PRP
TOTAL
0
0
0
5
0
5
4
0
4
7
5
12
16
5
21
19
10
29
26
19
45
70
24
94
69
30
99
216
93
309
         NOTE: Accomplishments shewn sr» th» turn of f lr*t and subsequent sctlons.
       SOURCES: CEBCLIS; Report to Congress on Progress Toward Implementing Supertund: Flscil 1»67, OERR, April 1»8».
     The OSWER Office of Program Management and Technology developed an OSC/RPM
Support Program during FY88 to address this lack of experience.   The program was
designed   to   assist  Superfund  management  and  OSCs/RPMs  in   improving  and
maintaining the quality of the response  actions.  This goal will be achieved by
encouraging Superfund workers  to  make   long-term service  commitments and  by
providing  continuing education support,   a certification program, a recognition
program, and rotational assignments.

     33.1  Worker Protection Standards

     EPA proposed  its  worker protection standards  on October  17,  1988  (53  FR
40692).  According to CERCLA section 121(f),  the  Agency must publish its  final
rule in the Federal  Register no later than 90 days  after OSHA  promulgates its
final standards, and the Agency met this statutory  deadline.  EPA's  final rule
was promulgated on June 6,  1989.
                                        57

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               Progress Toward Implementing Superfund:  Fiscal Year 1988

                                    Exhibit 3.2-19
                          The Remedial  Design Process
        EPA Selects Remedy!
         EPA Approves ROD
           Is Lead Design
         Party Different From]
            RI/FS Party?
NO
             Flnallzation of Design Agreement
              Lead Party Issues Statement
                 of Work for Design to
           Architectural and Engineering Firm
            Architectural and Engineering Firm
                Develops Design Package
              Based on Statement of Work
            RPM Provides
         Remedial Planning]
           Information to
            Appropriate
            Design Party
                                         Lead Party Schedules Design Reviews)
                                              at Pre-Determlned Intervals
                    Lead Party Conducts
                    Design Reviews with J
                       RPM Oversight
  NOTE: For Federal-lead RD«, the d*
-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     The Occupational Safety and Health Administration (OSHA) and EPA have agreed
that OSHA has the  lead  role in providing for the safety and health  of  workers
at hazardous waste sites.   OSHA proposed its final worker protection standard
on August 10, 1987 (52  FR  29620)  and published its final standard on March  6,
1989.   The Secretary  of Labor is  required to issue proposed standards  for the
health and safety protection of employees engaged in hazardous waste operations.
These provisions are designed to address factors such as worker training,  medical
surveillance, protective equipment, exposure limits, and informational programs.

     The  EPA regulations  are  identical to  the  OSHA  regulations  for  federal
employees, private employees, and state and local employees in  states that have
OSHA-approved state plans, but EPA's regulations apply only to those state and
local employees  in states  that do not have approved state plans under  section
18(c)  of the Occupational  Safety  and Health Act of 1970.
                                      59

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


4.0 SITE DISCOVERY AND ASSESSMENT

     During the site-discovery and assessment phase of Superfund response action,
EPA is  first  made aware of hazardous waste  sites.  The program then  conducts
preliminary assessments (PAs) and, if  appropriate,  site inspections  (Sis)  to
assess the extent of  the threat posed by contamination at  a  site and to decide
whether a removal action is necessary at the  site, and/or  to determine whether
the site merits listing on the NPL or  no further action.   At the end  of  the
fiscal year, there were 30,013 sites in the CERCLA Information System (CERCLIS)
inventory.     Exhibit  4.0-1   illustrates  historical  pre-remedial   program
accomplishments  and shows  the cumulative number of sites  in CERCLIS from  1980
through 1988.   The Agency exceeded  its goals for assessing hazardous waste sites
in FY88.  The  PA target  of  2,432 was exceeded by 21 percent for a total  of 2,884
completions.  The FY88 SI  target of 1,117 was exceeded by 11 percent for a total
of 1,237  completions.   Exhibit  4.0-1   also  charts the  pre-remedial   program
accomplishments  from  FY80  through  FY88.

     In addition, the Agency  published  several  guidance documents  and  proposed
rules  relevant  to  release   notification and  site-discovery  and  assessment
including:

     •    The Pre-Remedial Strategy for Implementing SARA;

     •    Preliminary Assessment Guidance for Fiscal Year  1988;

     •    The federally permitted  release proposed rule; and

     •    The continuous release proposed rule.

EPA also made substantial  progress during the fiscal year  toward completing:

     •    The proposed  revisions to the Hazard  Ranking System (HRS);

     •    A proposed  rule  designating extremely hazardous  substances
          (EHSs) as CERCLA hazardous substances;

     •    A proposed  rule  adjusting the reportable quantities (RQs)
          of the designated EHSs;

     •    A final rule  adjusting the RQs for  273  CERCLA hazardous
          substances; and

     •    A final rule  adjusting the RQs for  radionuclides.

     4.1 The Site Discovery and  Assessment Process

     EPA is made aware  of  possible hazardous waste sites in  a variety  of ways.
For example, individuals might report concerns about a  particular site  in their
neighborhood,   local  law   enforcement   officials  might  inform  the  Agency  of
incidents of midnight dumping, or a facility manager might  make  a formal report
to EPA.  Also, CERCLA section 105(d)  specifies that any individual  may  petition
EPA  to perform a  PA  of  a  site.    In  addition,  CERCLA  contains reporting
provisions that require persons  in  charge of a vessel or facility to immediately

                                      61

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
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-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1988


notify the National Response Center  (NRG) of releases  of hazardous  substances.
When a site has been identified as a place where hazardous waste may  exist,  it
is entered into EPA's CERCLA Information System (CERCLIS).

     Once EPA is made aware of a possible hazardous waste site,  the pre-remedial
phase of the  Superfund  program  begins.   A preliminary assessment   of existing
site  information provides the  basis   for  determining whether there  is  any
potential need for a removal action.   The PA is also used  to  set priorities  for
pre-remedial site inspections; to gather appropriate existing data  to  assist in
developing  a hazard ranking score;  and to  eliminate from further  remedial
consideration  those  releases  that  do not  threaten  public  health  or  the
environment.   In many  cases,  those sites  that are  eliminated from  remedial
consideration are deferred to the states.

     At sites warranting additional study, Sis are completed to further evaluate
potential hazard.  On the  basis of the  SI, a hazard ranking  system  (HRS)  score
is assigned  (where appropriate)  and  a  decision is made as to whether  the site
should be placed on the NPL.  Exhibit 4.1-1 illustrates the  stages  a  site goes
through during  the  site discovery and  assessment  phase of  Superfund  response
action.

     42 Notification

     Timely  notification of hazardous  substance  releases is  critical to  the
success of  the response  program.    As  noted above,  CERCLA  contains  specific
requirements  for reporting releases  of hazardous  substances.   Sections 103(a)
and  (b) require  that persons  in charge of a vessel or a facility from which a
hazardous  substance  is  released  in  amounts  equal  to or  greater  than  its
reportable quantity  (RQ) immediately notify the National Response Center  (NRC)
of such a release.

     42.1  National Response Center

     The  NRC  operates  a  24-hour  hotline  that  allows  for  the  immediate
notification of releases of CERCLA hazardous substances.  When the NRC receives
a report of a release,  it  notifies the  appropriate  federal response personnel.
Every release notification received by  the NRC and by EPA Headquarters,  Regional
offices, and the United States  Coast  Guard is entered  into the computerized
Emergency Response Notification System (ERNS).   ERNS is an  important  response
data base  in EPA's  documentation  and  tracking system.   It is a  nationwide,
centralized data base supported  by EPA,  the U.S. Coast 'Guard,  and the Department
of Transportation,  and maintained  by  the  Transportation Systems  Center.    A
detailed description of ERNS and  current  efforts  to upgrade  the  system  are
included in section 9.4.

     4.2.2  Reportable Quantities

     FY88 regulatory activity in the hazardous substance release notification
program consisted of a number of designation  and RQ adjustment and  reporting
rulemakings.  The Agency developed a proposed rulemaking designating  as CERCLA
hazardous substances  all  extremely  hazardous  substances (EHSs)  that are not
currently CERCLA hazardous substances.   Also,  in a related rulemaking,  EPA will
propose to adjust the RQs of the EHSs.  Section 102(b) of CERCLA establishes  one


                                       63

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            Progress Toward Implementing Superfund:  Fiscal Year 1988
                             Exhibit 4.1-1
           The Site Discovery and Assessment Process
                                                    Site Referred
                                                        to the
                                                      Removal
                                                      Program
Preliminary
Assessment
                             Pre-Score
          1


Results of the Preliminary Assessment
High
Priority
Medium
Priority
No Further Remedial
Action Planned
                                                       No Further
                                                        Remedial
                                                         Action
                                                        Planned
                             Response
                             by Others
SOURCE: Dtv»lop»d for this Report.
                                  64

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
pound as the statutory  reportable  quantity (RQ)  for all releases of hazardous
substances  except  those for  which RQs were  established  pursuant  to section
311(b)(4) of  the Clean Water  Act.    Section  102(a) of  CERCLA authorizes the
Administrator of EPA to  adjust RQs  for hazardous  substances and to designate as
hazardous substances those  which,  when  released  into  the  environment, may
present substantial danger to the public health or welfare  or  the environment.
Currently,   there  are   725  CERCLA  hazardous  substances.    A more  detailed
description of reporting requirement rulemakings is included in section 9.5.3.

     The Agency  also published  proposed  rules  during  the fiscal  year  that
explain the  reduced reporting requirements for continuous releases and interpret
the  definition of  federally permitted  releases  in  CERCLA  section 101(10).
CERCLA  section 103(f)(2)  assumes  that  if a  release  occurs  regularly  and in
relatively  stable  amounts,  federal  officials  do not need to  be notified each
time the release occurs to have  the necessary information to decide whether a
response is  desirable.   The continuous release rule, proposed on April 19,  1988,
establishes criteria for determining what constitutes a continuous release and
explains the   reduced  reporting  requirements  for  releases that  satisfy the
criteria.

     The federally  permitted  release  interpretive rule,  proposed  on July 19,
1988, clarifies the  federally permitted release  definition in CERCLA 101(10).
Releases of CERCLA hazardous substances that are  federally permitted are exempt
from CERCLA section 103(a) reporting requirements.  CERCLA  section 107(j) also
exempts a federally permitted release from  liability for  response  costs and
damages incurred due to the release.

     43 The Inventory of Sites (CERCLIS)

     As  noted  above,  when the  Agency identifies a  site as a  place  where
hazardous waste  may exist,  it  enters  information concerning the  site  into
CERCLIS.  CERCLIS,  which is maintained by the Office of Emergency and Remedial
Response, is  a national  inventory of all  sites potentially  appropriate for
listing on  the National Priorities List  (NPL).   As of September 1988, CERCLIS
contained data on  30,013  sites.   The Agency  completed PAs on 2,884 of  these
sites during the fiscal  year.   At the  end of this fiscal year,  only 2,944  sites
in the inventory required PAs.   In addition to  a site inventory,  CERCLIS also
provides key data elements for monitoring the financial and technical progress
of remedial, removal, and enforcement actions.

     During the fiscal  year,  the Agency began a  study to categorize the  sites
in CERCLIS  that have  been investigated  under  the Superfund program.   With
information gathered from the  study, EPA is developing  a data base that will aid
the Agency  in  drawing  conclusions  concerning the  type  of sites nominated for
cleanup.  The  data base also  will allow  the Agency  to  more  easily identify
policy  issues  of concern to  the pre-remedial program.    Each Region's  Field
Investigation Team (FIT) participated  in the study.  In October 1988, EPA began
a pilot program in  Region 10 to test the capabilities of the data base.  CERCLIS
is described in detail  in section 9.4.
                                      65

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
     4.4 Preliminary Assessments

     A preliminary  assessment  is the first step  EPA takes in determining  the
actual threat a site poses to the public and/or the  environment.   During a  PA,
the Agency, by collecting existing information, evaluates  the magnitude of  the
potential hazard at a site and determines the  source  and nature  of the release.
EPA collects information from its own files,  state and  local records,  and U.S.
Geological Survey maps.  Also,  telephone calls often are made  to persons in  the
locality  who  are  familiar with  the site.   Site visits  to search files  or
interview  site  managers are made when  appropriate.    On-site  surveys  of  the
actual area of contamination, however,  are performed at the discretion of  the
Regional Office.  On  the basis  of the PA,  EPA decides whether the site merits
further investigation.

     4.4.1  Statutory Goals Under CERCLA Section 116

     Section 116 of CERCLA specifies that PAs  are to  be  completed by January 1,
1988, for all sites listed in CERCLIS as of October  1986.   In January of 1988,
the Agency announced  that  it had met the statutory  target  for  completing PAs.
Achieving this goal required the completion of PAs for almost  1000 sites in  the
first quarter of  the  fiscal year.   Over the entire  fiscal year,  EPA completed
2,884 PAs.  There are now 27,069 sites  listed in CERCLIS that have completed
PAs.   Exhibit 4.4-1  illustrates the  cumulative percentage  of PAs  completed
through FY88.   Elimination of the PA backlog  allowed the Agency to establish a
new policy requiring that all sites entered into CERCLIS receive a completed PA
within one year.  This action was taken  to prevent accumulating a new backlog.

     The  Pre-Remedial  Strategy for Implementing  SARA published  by  EPA  on
February  2, 1988,  describes  the strategy  that  the Agency used to achieve  the
initial statutory requirements of SARA and reflects Agency goals for satisfying
the  subsequent  SARA requirements-.   The  strategy emphasizes the  importance of
acquiring enough information early in the pre-remedial process to enable EPA to
expeditiously determine which sites will require site inspections.  As a result
the PA has been expanded in scope and involves more site-specific research.  The
Agency also is now considering MRS factors  at  both the PA and SI stages in order
to help  develop  a projected HRS score.   Sites that do not require  a  removal
action and have  no probability  of being listed on the NPL are  designated  "No
Further Remedial Action Planned  (NFRAP)" and  will  receive  no  further Superfund
evaluation.   These sites, however,  often are  deferred to states  for  further
assessment.  Approximately 11,000 sites  have  been  so designated.

     4.4.2  Reassessment of Low-Priority Sites

     During the fiscal year, the Agency also conducted a full-scale reassessment
of sites  that  previously  had  been assigned low priority for  site inspections.
Approximately 5,000 existing PAs were re-evaluated in order to  more accurately
assess  the SI workload.   Through  the  re-evaluation,  EPA determined  that no
further remedial action was required at approximately 3,000 low priority sites.

     4.43  Preliminary Assessment Guidance

     EPA  issued interim guidance on  PAs  in January 1988.  The  interim guidance
applies to all PAs  that will be  conducted  at  sites  included in  CERCLIS,


                                       66

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    Exhibit 4.4-1
                      CERCLIS Sites with Preliminary Assessments
                           Completed Through Fiscal 1988
                                    (cumulative)
                                                Total CERCLIS • 30,013

                                                |   | FY 1981-1987

                                                   PY 1988

                                                   Remaining
              SOURCE: OSWER Annual Report, FUcil 1988, November 1988.
regardless of the date of entry into the system.  The guidance reflects the pre-
remedial program goals  described in the Pre-RemedLal Strategy for  Implementing
SARA.  In the guidance, the Agency modified the PA  to identify more effectively
those  sites  that  require site  inspections (Sis).   The  level of effort  for  an
average PA  is increased  from 50 hours  to approximately  75  hours.  Also,  the
guidance incorporates activities such  as on-  or off-site reconnaissance,  the
application  of  technical evaluation criteria  and  professional judgment,  site
visits  to  search  files or  interviews  of  site managers,  and other  technical
factors for prioritizing sites for an SI.  The revisions to the HRS  had not been
proposed  as  of  January  1988,  thus,  the  guidance is  interim.    The Agency,
however, made substantial  progress  during  the  fiscal  year in  revising  the
interim  PA  guidance  to  incorporate the proposed  changes  in  the HRS.    EPA
conducted studies  in  the Regions to  determine the best method of performing PAs
under  the revised  HRS.   The  guidance will be finalized once  the changes  in the
HRS are finalized  and effective.

     4.4.4  Prescore

     To  bring  consistency  to  the  application  of scoring factors  to  site
conditions and to  facilitate consideration of  the HRS during the PA as well  as
the  SI,  EPA  is developing  a computer  program called  Prescore (formerly  Site
Screening Analysis).  Prescore uses site-specific data to project HRS scores for
a site.  Developing probable HRS  scores is a key step when making  decisions  as
to whether remedial action will be appropriate for  a given site on  which  a site
evaluation  is being  performed.    Prescore  not  only  provides  rationale  and
documentation to back up decisions regarding additional activities at sites, but
also  allows  variables  to be adjusted  thus  enabling  the  scorer  to  see how
different factors  will  affect the projected  HRS  score.   Prescore  software has
been distributed to the Regions and is  in the process of being field  tested.
                                       67

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Progress Toward Implementing Super-fund: Fiscal Year 1988
                                        Exhibit 4.6-1
                          Site Inspections Completed Through Fiscal 1988
                                                Totll Compl.Ud • 9,022

                                                B FV 1*88

                                                I  | FY 1981-1*87
                       SOURCE: OSWER Annutl R«port, Flicil 1*88, Nov«mb«r 1(88.
     4.5 Site Inspections

     If  the  PA  indicates   that   a
suspected   release   of   hazardous
substances may threaten human health
or the environment,  EPA orders a site
inspection  (SI).    Approximately  30
percent or 9,022 of  the  sites entered
in  CERCLIS  through  FY88  now  have
completed Sis.  The Agency  completed
1,237 Sis during  FY88.  Exhibit 4.5-
1 compares  the total  number of  Sis
conducted  in  FY88  with  the  number
conducted in previous fiscal years.

     The  Agency  exceeded  its  FY88
target for completing Sis  by  120.  All
of  the  Regions  contributed  to  this
success by equaling or exceeding their
respective  goals.

     4.5.1  Screening Site Inspections

     In order  to  expedite the SI process  the  Agency divided it into two phases.
EPA distinguishes between  screening  site inspections  (SSIs) and  listing site
inspections (LSIs).  SSIs consist of a visual inspection of the site and include
collection  and chemical analysis of a limited number of samples of environmental
media.  The purposes of the  screening  SI are to identify those releases that pose
no  current or potential threat to public health and the environment; to determine
whether there  exists  any  immediate threat to  persons living or working near the
release that might necessitate an immediate  removal action; and to collect data
to  help determine whether the site  should be included on the National Priorities
List.

      EPA made  substantial progress  in the fiscal year toward completing guidance
on  the SSI data collection requirements and procedures under the proposed revised
HRS.  The  guidance  will be  finalized once the changes in the HRS are effective.

      4.52 Listing Site Inspections

      The  Agency  makes  a  decision  at the  completion of the  screening SI as  to
whether a  listing  SI will  be  conducted.  To  determine which  sites should  be
placed on the  NPL,  EPA  and  states use a special scoring system called the  Hazard
Ranking System (HRS).  Revisions to the HRS, required by CERCLA section 105(c)(l)
as  amended,  are  currently  being  completed.    Section 9.5.1  provides complete
details on the HRS revisions.   The HRS score takes  into  account the types and
 quantities of waste  at  a  site,  the extent  of contamination  that has already
 occurred (especially of groundwater), and the number of people  living or working
near the  site who could be  exposed to hazardous chemicals  escaping from it.  The
 score is achieved by assigning numerical values  to threats posed to  the  public
 and the environment  by the  migration  of a hazardous  substance through  ground
water,  surface water,  and  air.  Any  site that is assigned  a score of 28.5  or
higher is  eligible for placement on the NPL.  The value  of 28.5 was chosen  to
                       68

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
yield  an original  NPL  of at  least 400  sites,  not because  it  represents a
threshold in the significance  of the risk presented by the site.   During  the
listing  site inspection phase,  the Agency actually scores the  site  using  the
hazard ranking  system.
                                       69

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
5.0   THE NATIONAL PRIORITIES LIST OF SITES

     The National  Priorities List  (NPL)  identifies abandoned  or  uncontrolled
hazardous waste sites as target sites  for  long-term  remedial action.  At the end
of fiscal  year 1988, 797  sites were  listed,  and  378  sites were  proposed for
listing on the NPL,  for  a  total of  1175 NPL sites.   The  list  includes 32 final
and 30 proposed  federal facility sites.   Exhibit 5.0-1  lists  federal and non-
federal NPL  and  proposed sites by  state  and EPA Region as of  September 1988.
Exhibit 5.0-2  is a map  showing  total  NPL  sites by  state  as  of September 1988.

     During  the  fiscal  year, the Agency  proposed  229  sites and reproposed 13
sites for listing.  The balance of sites was proposed in previous  fiscal years.
In addition, EPA deleted five sites from the  list  and announced its  intent to
delete nine additional sites.  The Agency  also  announced  plans to drop 30 of the
sites proposed for listing.   In addition, EPA:

     •    Took comment  on  the  idea  of expanding the NPL  deferred listing
          policy;

     •    Added  to the  criteria for listing Resource Conservation  and
          Recovery Act  (RCRA)  sites;

     •    Modified its policy  for determining  when  a RCRA facility
          owner/operator is unwilling to  pay for corrective action;  and

     •    Sought comment on a modified policy  for determining when a RCRA
          facility owner/operator is  unable to pay  for corrective  action.

     5.1  Sites Added to the National Priorities  List

     On  June 24,  1988,  EPA published  its   seventh  update  of  the NPL  in the
Federal Register.  This  notice  proposed 229 new sites and the expansion of one
final site, and it reproposed four previously proposed sites.   In addition, the
Agency stated its intention to list 13 RCRA sites that were  previously proposed
for the  NPL and to drop  30 RCRA  sites  from  the  proposed NPL.   The  notice
including this update also announced  an expansion of the criteria for listing
RCRA sites on  the  NPL.   EPA also made substantial  progress towards  completing
updates number eight and number nine  during the fiscal year.

     Prior  to  promulgation  of  the revised MRS,  the  Agency  expects to  have
finalized  updates  eight,  nine,  and  the remaining proposed  sites  from  all
previous updates.

     5.1.1 Methods for Listing Sites

     Generally,  the Agency updates  the NPL  at  least once each year.   Sites are
added to the NPL on the  basis  of the hazard ranking score (HRS) assigned to them
after a  site inspection is completed.  The factors the Agency considers  when
assigning an HRS score are the  quantities and  toxicity of the  wastes  involved,
the number of people potentially exposed, the  likely pathways  of exposure, and
the importance and vulnerability of the underlying supply of ground water.   Any
site that scores 28.5 or higher is  eligible  for placement on  the NPL.   The
                                       71

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     Progress Toward Implementing Superfund: Fiscal Year 1988
                       Exhibit 5.0-1
National Priorities  List  Sites by  State or Territory
               As of September 1988

Region
1






2




3







4








5






SOURCES :

State
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Total
New Jersey
New York
Puerto Rico
Virgin Islands
Total
Delaware
District of
Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Total
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Total
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Total
National Priorities
Final
Non-Federal
7
5
20
13
8
2
55
94
62
8
0
164
12
0

6
60
10
5
93
8
32
3
10
2
9
12
8
84
15
24
58
39
28
32
196
Proposed
Federal
0
1
1
0
0
0
2
2
1
0
0
3
0
0

0
1
1
0
2
1
0
1
0
0
0
0
1
3
2
0
0
1
0
0
3
List, Supplementary Lists
Non-Federal
7
2
1
2
1
6
19
13
13
0
0
26
8
0

2
34
11
1
56
2
17
9
7
1
11
9
4
60
20
13
23
0
3
7
<56
Federal
0
0
0
0
0
0
0
1
0
1
0
2
1
0

2
2
0
0
5
1
0
0
0
0
1
0
0
2
2
0
0
0
1
0
3
and Supporting Materials, OERR,
Total
14
8
22
15
9
8
76
110
76
9
0
195
21
0

10
97
22
6
756
12
49
13
17
3
21
21
13
149
39
37
81
40
32
39
268
June
1988: 53 FR 33811. September 1. 1988.







                          72

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     Progress Toward Implementing Superfund: Fiscal Year 1988

                       Exhibit 5.0-1
                        (continued)
National Priorities List Sites by State or Territory
               As of September 1988

Region
6





7




8






9









10




TOTAL
SOURCES

Final
State Non-Federal
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Total
Iowa
Kansas
Missouri
Nebraska
Total
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Total
American Samoa
Arizona
California
Commonwealth of
Marianas
Guam
Hawaii
Nevada
Trust Territories
Total
Alaska
Idaho
Oregon
Washington
Total
ALL REGIONS
National Priorities List
9
6
4
5
20
44
1
7
12
2
28
12
8
1
1
3
I
26
0
5
40
0

1
0
0
0
46
0
4
4
20
28
765
Prooosed
Federal
0
0
0
1
1
2
0
0
2
1
3
I
0
0
0
2
0
3
0
0
8
0

0
0
0
0
8
0
0
1
3
4
32
, Supplementary Lists
Non-Federal
1
4
4
5
6
20
16
4
7
2
29
2
2
1
0
5
1
U
0
3
37
0

0
6
0
0
4<>
1
0
2
12
J5
348
Federal
0
1
2
0
1
4
0
0
0
0
0
1
0
0
0
1
0
2
0
1
3
0

0
0
0
0
4
0
0
0
8
8
30
and Supporting Materials, OZRR,
Total
10
11
10
11
28
70
23
11
21
5
60
16
10
2
1
11
2
42
0
9
88
0

1
6
0
0
104
I
4
7
43
55
1,175
June
1988: 53 FR 33811. September 1. 1988.







                           73

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                Progress Toward Implementing Superfund:  Fiscal Year 1988
0
                                                                                        «
                                                                                     Q. •"
o
IA .0
X
u
                                            74

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
number of  sites  that have been  added to the NPL  annually for the  years  FY83
through FY88 is shown in Exhibit 5.1-1.

                                   Exhibit 5.1-1
                   HISTORICAL NATIONAL PRIORITIES LIST SITES
Annual Number
Fiscal year
1988
1987
1986
1985
1984
1983
of Sites
Added
0
99
170
3
132
406
Cumulative
Total
797*
802
703
541
538
406
* This total reflects the fact that eight sites were deleted
from the NPL in FY86 and five sites were deleted in FY88.
SOURCES: Report to Congress on Progress Toward
Implementing Superfund: Fiscal Year 1987. OERR,

April 1989: National
Supplementary Lists
OERR. June 1988: 53

Priorities List.
and Supporting Materials.
FR 33811. September 1. 1988.

     EPA Regional  offices,  states, and  Indian tribes jointly  identify sites.
EPA Regional offices conduct a quality control review of state-nominated sites,
and may assist in the investigation, monitoring,  and scoring these sites.   EPA
Headquarters conducts further quality assurance audits to ensure scoring accuracy
and consistency.

     Sites  also  may be listed  on  the  NPL by  state  designation.  A  state may
designate a single site as the state's top priority.   A state top priority site
will be listed on the NPL even  if  its HRS  score  is lower then 28.5.

     Also,  in rare  instances,  EPA may list, under section  300.66(b)(4) of the
NCP, certain sites  with  an  HRS  scores  below 28.5.   Such sites  may qualify for
the NPL if  all of the following occur:

     •    The Agency for Toxic  Substances  and  Disease Registry of the
          U.S. Department of Health and  Human  Services has  issued a
          health advisory that  recommends  restricting access of persons
          to the site;

     •    EPA determines that the  release  poses  a significant threat to
          public health; and
                                       75

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     •    EPA anticipates that it will be more cost-effective to use
          its remedial authority than to use its removal authority
          to respond to the release.

     EPA proposes sites for  listing  on  the  NPL and solicits public comment  on
the listing  in  the  Federal Register.   Based on the  comments  and further EPA
review, the Agency determines final scores and lists  as final those sites  that
meet the listing criteria.   When proposed sites  become final, they are  placed
on  the  NPL  in  groups of  fifty  on  the basis of  their assigned  HRS scores.
Federal facilities are listed in a separate section in similar groups.

     Because EPA reviews proposed sites on a case-by-case basis, not  all sites
from a  specific  update will be finalized simultaneously.   For example, final
rule number  seven will include sites  from update number six and update  number
nine.   Final rules number eight and number nine will  consist of sites proposed
in updates number seven and number eight, and any previously proposed sites  that
have not yet been finalized.  Exhibit 5.1-2 illustrates the  NPL listing process.

     52  Sites Deleted from the National Priorities List

     The Agency  initiated deletion activities for  11 sites during the  fiscal
year.   Five  sites were actually deleted from the list.

     •    April 18,  1988 deletions:

          Mountain View Mobile Home Estates, Globe, Arizona;
          Middletown Road Dump, Annapolis, Maryland;  and
          Harris (Farley Street), Houston, Texas.

     •    September 1, 1988 deletions:

          Tri-City Oil Conservationist, Inc., Tampa,  Florida; and
          Varsol Spill, Miami, Florida.

Exhibit  5.2-1  lists  the sites that  have  been deleted from the  NPL  since  the
inception of Superfund.

     The Agency deletes a site from the NPL when it determines that no further
response action is required at the site.  In order  to make  that determination,
the Agency will consider whether any of the following three criteria  have  been
met:  (1) EPA and the  state must determine that the PRPs or other parties  have
taken all appropriate  response action at  the site;  (2) the  Agency or  the state
must  have  implemented all  appropriate  fund  financed  response  action,   and
determined  that  no  further cleanup by  PRPs  is necessary;  or  (3)  EPA and  the
state must  have  concluded,  based  on  the remedial investigation,  that the  site
poses no significant  threat to human health or the  environment and, therefore,
does not warrant remedial action.

     When the EPA Regional Administrator has approved the Site Close Out  Report
(SCOR), the Agency may begin deletion activities for a site.  First, the  Region
and the state must agree  that the site  is  ready  for deletion.   Second,  the
Region  must  prepare a deletion docket that contains  all pertinent  information
supporting  the Region's recommendation  that the site  be  deleted.  When  the

                                      76

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
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-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   Exhibit 52-1
              Sites Deleted from the National Priorities List

Site Name
Gratiot County Golf Course
Friedman Property
Enterprise Avenue
Lehigh Electric and Engineering
PCS Spills
Morris Arsenic Dump
PCS Warehouse
PCB Wastes
Taputimu Farm
Middletown Road Dump
Harris (Farley Street)
Mountain View Mobile Homes

State
Michigan
New Jersey
Pennsylvania
Pennsylvania
North Carolina
Minnesota
Mariana Islands
Pacific Islands
American Samoa
Maryland
Texas
Arizona
Tri-City Oil Conservationist Florida
Varsol Spills Florida
SOURCE: Superfund Site Completions and Deletions from the National

Region
5
2
3
3
4
5
9
9
9
3
6
9
4
4
Priorities
Deletion
Date
09/08/83
03/07/86
03/07/86
03/07/86
03/07/86
03/07/86
03/07/86
03/07/86
03/07/86
04/18/88
04/18/88
04/18/88
09/01/88
09/01/88
List. HSCD/OERR.
October 25, 1988.
deletion docket is complete, the Region must prepare a notice of intent to delete
that is published in the Federal Register and in a newspaper that is  available
in the area of  the site.   The  Region must announce  in the notice published  in
the local newspaper that the public  is  allowed  30 days in which to comment  on
the site deletion.  The Region should also inform all  state and  local officials,
PRPs,  appropriate federal  agencies,  enforcement personnel  from the Office  of
Regional  Counsel  (ORC) ,  and  any local  repositories that  the site  is  to  be
deleted.

     The  Region also  is required to prepare a  summary of all  the local and
national comments  received in response to the notice of intent to delete.  The
summary  should  include  descriptions  of  comments received during  the public
comment period  and of  transcripts from any public meetings,  and responses  to
all of the comments.

     When a site is deleted  from the NPL it does not  need to  be relisted for
the Agency or PRPs  to undertake additional response action if conditions at the
site warrant  such action.    If,  however,  the  Agency  decides that  the site
continues to threaten human health or the environment, EPA may relist the site
without rescoring it.   In addition,  the Agency may continue to try and recover
costs incurred while cleaning up a site after it is deleted from the  NPL.
                                      78

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
     53  Revisions to Listing Policy

     In  fiscal 1988,  the Agency solicited comments on whether  EPA should take
an expanded  approach for deferring  sites  to other regulatory  authorities  for
needed  corrective  action.    The Agency  also  expanded  the  NPL/RCRA  listing
criteria,  and  revised   the  policy  on   determining when  a   RCRA  facility
owner/operator is unwilling to pay for corrective action; EPA also took comment
on the  advisability of modifying the  policy for listing RCRA  sites  where  the
owner or operator is unable to  pay for corrective  action.

     53.1 Deferred Listing Policy

     In  the past, the  Agency has  deferred  the listing of sites  on the NPL when
certain  other authorities were  found to be  capable of accomplishing needed
corrective action.  To date, this deferral  policy  has been limited to sites
that can be addressed  by the Subtitle  C corrective action authorities of the
Resource Conservation  and Recovery Act (RCRA) or sites that are subject to
Nuclear Regulatory  Commission regulation.   In the  proposed revisions to the
NCP, the Agency solicited comment on a policy to expand  deferral to include
other federal and state  authorities.   The  Agency will not go forward with any
expanded deferral approach until  the significant public  and Congressional
concerns have been  fully addressed and resolved.

     532, Additions to Criteria for Listing RCRA Sites

     In addition to updating the NPL  in the June 24th proposed rule, noted above,
the Agency amended  the policy regarding RCRA sites by adding new categories of
RCRA sites as  appropriate for  listing  on  the NPL.  Under  current  policy,  the
Agency  recognizes  three  categories  of  RCRA facilities that appear  to  warrant
listing  on the NPL:

     •    Facilities owned by persons  who  are bankrupt;

     •    Facilities that have  lost  RCRA interim status  and for
          which there  are additional indications that the owner or
          operator  will  be unwilling to undertake  corrective action;
          and

     •    Facilities,  analyzed  on a  case-by-case basis,  whose
          owner/operators have  demonstrated a clear history of
          unwillingness  to undertake corrective action.

RCRA sites are currently appropriate for listing  only if necessary corrective
actions  under RCRA  are unlikely to  be performed,  or  if  certain other criteria
for listing are met.

     The four new categories  of  RCRA  sites  are in accordance with the NPL policy
concerning sites  subject to  Subtitle C corrective  action  authorities of RCRA.
First,  the Agency has  decided  to place on the NPL "non-  or late-filers" under
RCRA that also score 28.50 or more on  the  HRS.   These are facilities that were
treating, storing,  or  disposing of hazardous waste  after November 19, 1980,  but
did not  file  a Part A permit  application by  that date  and have little  or no
history  of compliance  with RCRA.


                                       79

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
     Second, the Agency has  decided to add to the NPL RCRA facilities  scoring
28.50 or more and that have permits that pre-date the Hazardous  and  Solid Waste
Amendments  (HSWA)  of  1984.   Permits  acquired prior  to HSWA  do  not  require
owners/operators of facilities  to  perform corrective action for releases  from
solid waste management units, and the Agency does not have the authority, until
the  permit  is  renewed,   to  modify  such  pre-HSWA  permits  to  include  RCRA
corrective action.  For such sites,  it  could be  1994 before the Agency  will be
able to modify  some permits  to  include corrective action.  EPA believes it is
appropriate to include on  the NPL facilities with pre-HSWA permits that have HRS
scores greater than or equal to 28.5.

     Third, EPA had decided to include on the NPL these RCRA facilities  scoring
28.50 or more that are "protective filers."  Protective  filers are  facilities
that  filed Part  A permit  applications  as  treatment,   storage,  or disposal
facilities  (TSDFs)  as a  precautionary measure  only and which  are, in fact,
generators,  transporters,   or  recyclers   of  hazardous  waste.     Presently,
protective filers are not  subject  to Subtitle C  corrective action authorities.
Thus, the Agency will propose them for  listing on  the  NPL.

     The fourth category of  RCRA sites  that EPA  has  decided is  appropriate for
inclusion  on the  NPL  is  converters   (scoring  28.50  or more  on  the HRS).
Facilities  fall under the converter  category  if they  previously   treated or
stored  RCRA  Subtitle C  hazardous  wastes  but  now  only  generate  hazardous
substances.   Although EPA,  under  RCRA section  3008(h),  has  the authority to
compel corrective action at  such sites,  converters have  not been a  priority of
the RCRA corrective action program.  The program focuses primarily on treatment,
storage,  and disposal facilities.    Thus,  EPA has  not  routinely reviewed
converters under RCRA Subtitle C, and the Agency believes that such sites should
be included on  the NPL where they  present a threat to human health  or  welfare
or the environment.

     533  Revisions to the Unwillingness and Inability-to-Pay Criteria

      EPA's original  policy  for deferring RCRA facilities from the  NPL stated
that RCRA  Subtitle C  facilities -- those facilities treating,  storing,  and/or
disposing of hazardous wastes -- would not  be placed on the NPL, and therefore
Fund money could not  be expended for cleanup, unless  the owner or  operator of
the  facility was  either   unable or unwilling  to pay  for  corrective  action.
During the fiscal year, EPA published a revised policy for determining an owner
or operator's  unwillingness-to-pay,  and took comment on a  draft   policy for
determining an owner  or operator's inability-to-pay.

     533.1  Unwillingness

     The Agency issued a revised policy on  August  9,  1988, on how  to determine
that an owner or operator of a RCRA facility is unwilling to perform corrective
action  at  a facility.    Under  the  previous   policy,  determination  of  the
unwillingness of an owner or operator to undertake corrective  action was  done
on a case-by-case basis, often took several  years, and required EPA to establish
that the owner  or  operator had  a history of failing to  take corrective action
required by Agency or state  orders or  permits.
                                       80

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     Under the revised policy,  an owner or operator's unwillingness generally
will be determined  by more objective means such  as  failure to comply with  an
order after the order is upheld in an administrative appeal or by a court.

     5332  Inability

     On August  9,  1988,  the Agency  also proposed  to  revise the  policy for
determining when a facility  owner/operator is unable  to  pay  for corrective
action.  Currently,  only an owner/operator who declares bankruptcy is considered
unable to  pay.   EPA  proposed two options  for  the inability-to-pay criteria.
The first  option  the  Agency  is  considering involves  comparing the cost of the
site remedy proposed  by  EPA with the  financial status  of the owner/operator.
The comparison (and subsequent listing,  if appropriate) would be made only after
a RCRA Facility Investigation (RFI)  and Corrective Measures Study (CMS) for the
facility are completed and an EPA-proposed remedy  is publicly available.  This
would  ensure  that the cost of  cleanup is fairly  well  established before the
comparison is made.   EPA  is  proposing  to place a  RCRA  site on the NPL if the
estimated cost of the  EPA-proposed remedy is greater than the tangible net worth
of the owner/operator.

     The Agency  recognizes,  however,  that  the owner/operator or a citizens'
group may successfully challenge EPA's  selection, and a lower cost option -- one
that the  facility could afford to  pay --  might  eventually be  selected.    To
accommodate such situations,  EPA also proposed an  alternative  criterion.  Under
this alternative, EPA would place a RCRA site on the NPL  if the  estimated cost
of the least expensive remedy considered in the  CMS (excluding "no action"),  or
the remedy ultimately selected after any appeals,   is greater than the tangible
net worth of the owner/operator.

     In response to public comment on the  proposed rule,  the Agency is expected
to further  clarify  certain aspects of  the  proposed  inability-to-pay criteria
    re publication of a revised policy.
co rurcner  ciariiy certain aspects or
before publication of a revised policy.
                                      81

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


6.0 ENFORCEMENT PROGRAM ACTIVITIES

     Enforcement efforts have been critical to the Superfund program's progress,
helping to  bridge the  gap  between  the huge  costs  of cleaning  up all of  the
serious hazardous waste sites in the nation and Superfund1s  limited financial
resources.   The  role of potentially  responsible  parties (PRPs)  in  conducting
Superfund site cleanups has become increasingly important.  Overall, in FY88  the
Superfund enforcement program met or exceeded most targets,  resulting in record-
setting accomplishments for the year.  From the beginning of CERCLA through  the
end of the fiscal year, EPA has reached settlements for PRPs to conduct responses
worth more than one billion  dollars.  These responses include emergency removals
of hazardous substances, remedial investigation/feasibility studies, and remedial
actions.  The  entire  enforcement process  is illustrated within  the  context of
the Superfund cleanup process  in  Exhibit 6.0-1.

     6.1 Overview of Enforcement Activities

     RI/FS  "first starts" by  PRPs exceeded the  1988  target  of 35 sites, with a
total  of  48.  Exhibit  6.1-1 demonstrates  the  increased role  of PRPs in  the
conduct of first start RI/FSs.  Whereas PRPs conducted only 38 percent of  first
start  RI/FSs  in  FY87,  they conducted 48 percent  in FY88,  and are expected to
conduct 55  percent  in  FY89.   RODs  based  on  PRP-conducted RI/FSs  increased
significantly  during  the fiscal  year,  for a  total  of 43  initial RODs and 7
subsequent RODs signed.   PRPs  undertook 21 remedial action starts, exceeding  the
target  of  20.   Currently,  EPA  is working  toward the  goal  of having PRPs
responsible for  funding 50 percent  of all cleanups.

     Under  Superfund, PRPs  are liable for  either  cleaning up hazardous waste
sites themselves or reimbursing the  government or other PRPs who do the work  for
expenses incurred in cleaning up the sites.   EPA uses its enforcement authority
to identify, notify,  and negotiate with PRPs in an attempt to reach a settlement
whereby PRPs either conduct or pay  for cleanups.   EPA may  negotiate voluntary
cleanups  at different  points in the clean-up process.    The Agency  usually
negotiates with the PRPs involved  (1) before the RI/FS,  in an attempt to get them
to perform the study as well as carry out  the  selected remedy, or (2) after  the
RI/FS, in an attempt to get the parties to implement the selected remedy.

     In the  case where  settlement negotiations do  not result in  a  successful
agreement, EPA has two alternative courses of action it can pursue.  The Agency
may either  issue an administrative  order  and/or thereafter seek  a court  order
under CERCLA section 106 to require PRPs to perform  the cleanup  themselves,  or
it can use Superfund money to  finance a government action and then seek recovery
of such costs from PRPs through negotiations  or the  courts  under section  107.

     6.1.1  Potentially Responsible  Party Involvement

     The search for PRPs is the cornerstone of the Superfund enforcement program.
This  is the first step  in  the enforcement process, beginning after  the site
discovery.  An initial,  preliminary  search to identify obvious PRPs is essential
at this time, especially at removal sites where immediate action is  necessary,
to determine whether  PRPs are available to  perform or finance the cleanup.   A
formal PRP search is  also conducted  later  on in the  enforcement process, at  the
                                      83

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                       Exhibit 6.0-1
           Sequence of Enforcement Actions in the Remedial Process
                                       Site Discovery
Preliminary
PRP Search
                                   Preliminary Assessment/
                                      Site Investigation
                                                                     PRP Search
                                National Priorities List Listing
                                   General Notice Letters
                                RI/FS Special Notice Letters
                                     RI/FS Negotiation
                               Fund RI/FS
                                RD/RA Special Notice Letters
                                     Record of Decision













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::,,,,::::.:,,::.:,::,,::,:;f:,:::::::::::,:,;:.:,,,::::::,,:
Fund Remedial Design (RD)
Fund Remedial Action (RA)
:•.•:•:•:•:•:-.-:•:•:• :-::-:-:-:-:-:-:-i-:-:-:-:v:-:-:-:-:-:-:-:-: :•:•:•:•:•:•
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Cost Recovery





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PRP Remedial Design
PRP Remedial Action
:•:•:•:•: :•:•: :•:•:•:•:•:•:•:•:•:•:•: :•:(:•:•:•:•:•:•:•:•:•:•:•
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SOURCE: QAO Report RCED-89-40BR "Sup«rfund: InUrlm A«»«t»m»nt of EPA'* Enforcement Program,* October 12, 1988.


                                        84

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


time a site is submitted by  an  EPA  Region to Headquarters for inclusion on the
NPL.

     During the search effort, EPA tries to establish the  liability and financial
capability of those responsible for  site cleanup.  PRPs may include individuals,
corporations, or other entities  that are past or present owners of sites, as well
as generators or  transporters or those  who arranged for disposal of waste that
contributed hazardous  substances  to the site.  EPA  then informs PRPs of their
potential liability  through  the use of general notice  letters,  and gives them
an opportunity  to conduct the  site  cleanup work.   When  PRPs are  unwilling to
undertake the  work,  EPA may attempt to negotiate  an agreement, and may take
enforcement action to  compel participation in cleanup efforts  if  an agreement
is not reached.

     The PRP search thus supports EPA's policy to secure  cleanups by PRPs instead
of using Superfund monies.   Even when Superfund monies  are  used to finance the
cleanup, a PRP  search  must be completed for cost recovery  actions  to be taken
in the future.  To ensure  the timeliness  and adequacy of PRP searches, EPA has
hired at least one civil investigator for each of its  ten Regions.  In addition,
the Agency is auditing  certain contract PRP searches  to determine their adequacy.

     6.1.2  Guidance  on Potentially  Responsible Party Involvement

     In  addition,  in  FY88,  EPA   issued  Guidance   on   Funding  CERCLA  State
Enforcement Actions at NPL Sites.  This  guidance addresses the conditions states
must consent to when applying for and  receiving cooperative agreement funding
to  conduct  enforcement  activities.  These activities  include PRP  searches,
negotiating settlements, and oversight  of PRP activities.  In FY89 EPA plans to
issue an  additional  important  guidance document which  will deal with  issues
surrounding PRP involvement in the enforcement process.  Guidance on Potentially
Responsible  Party Participation  in  Remedial  Investigations and  Feasibility
Studies establishes policy and procedures  for  governing PRP involvement in RI/FS
under CERCLA.  It addresses,  in particular:  circumstances under which PRPs may
conduct  the RI/FS,  development  of enforceable  agreements  governing  RI/FS
activities,  PRP  oversight,  dispute resolution,  correction  of RI/FS  process
deficiencies, and PRP  participation in  the Agency's  RI/FS activities.

     6.13  Enforcement Under CERCLA Section 106

     EPA  can use its  authority under  section  106  of CERCLA to  issue  an
administrative order to compel  a PRP to perform removal  or  remedial actions at
a site.   An administrative order summarizes the  terms of a  clean-up agreement,
including sampling requirements, clean-up techniques, and timetables.  EPA either
negotiates the  administrative  order with  the PRP,  or  develops the  order  and
issues it on its own.   For remedial  actions, agreements with PRPs to conduct the
work must be in the form of  a judicial  consent decree.

     Progress During Fiscal 1988

     In April 1988,  the Administrator requested that each Region  identify one
or'more section 106 cases for a unilateral  enforcement  action,  in  an effort to
increase PRP involvement in site clean-up activities.  The Office of Enforcement
and Compliance Monitoring  (OECM) and OSWER undertook an initial  screening of


                                      85

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


sites, looking  especially  at NPL sites where Records  of Decision (RODs) were
signed or would be signed  in the  near  term.   As a result, a total of 22 sites
were identified for section  106 referrals.   By  the end of FY88, four of these
cases were settled and  two were referred.   Of the remaining 16 sites, several
are in the final stages of settlement negotiations;  several others have had  the
projected ROD signature date delayed and are thus not yet  ready for referral.

     In addition, EPA issued 14 unilateral administrative  orders under section
106 during FY88  for  RD/RA with a potential value  of  $136 million.   Of these,
seven resulted  in RD/RA  settlements with an  approximate total value  of  $50
million, one resulted in a settlement in the  form of a judicial consent decree,
two cases were referred to the Department of Justice (DOJ) for further action,
and the remaining orders are waiting for a PRP response.  The Agency referred
one additional case to DOJ for injunctive relief for an RI/FS  and RA,  the value
of which has yet  to be  determined.   If violated, these orders are enforced by
the courts.

     A total of  116 administrative orders were issued for removal activities with
a potential value of  over $78 million  dollars.   This  number  is a 300 percent
increase over  the number  of  FY87 removal orders.  Of  the 116 administrative
orders, 94 resulted in compliance, with a total  value  of over  $67 million.   One
hundred and two  of these administrative orders resulted in actual removal starts.
For RI/FS activities,  a total of 77 administrative orders were issued with  a
total value  of  over $85 million  (Exhibit 6.1-2).  The  combined  total of  207
administrative  orders  represents a  100 percent  increase over  the  100 total
administrative  orders  issued during  FY87.     The  dollar  amounts  cited   for
settlements, not amounts reimbursed  to  the Fund,  represent the estimated value
of the remedial activities PRPs have agreed to  undertake.

     Initiatives to Increase the Number of CERCLA Section 106 Actions

     During February 1988, senior Agency and DOJ officials met to explore  new
methods  to  increase  the  effectiveness of  the Agency's  use of  section  106
authorities.   A workgroup was  established to  investigate EPA's  policies  and
practices to assure the proper balance of incentives and disincenbives for PRPs
at  Superfund sites.    This  workgroup  concluded that  the use  of unilateral
administrative  orders will frequently  provide a strong  incentive to settlement
and recommended that there should  be  a  bias in favor of issuance of  a unilateral
administrative  order where some or all of  the PRPs  are  unwilling to enter into
settlements.

     Key Action

     In March 1988,  a consent decree was negotiated to  resolve  Inmar Associates'
failure to  comply with  a CERCLA section 106 order  issued by  EPA.  The consent
decree, lodged  in district court, requires that a lump  sum payment of $545,000
be made by Inmar.  This resulted in the largest  penalty,  $315,000,  ever imposed
by  EPA upon  a  party  pursuant to  CERCLA section  106(b).   In addition,  the
settlement  resulted  in a  full  100  percent reimbursement of  the approximately
$152,000 in response costs incurred  at the waste  site.
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            Progress Toward Implementing Superfund: Fiscal Year 1988
                             Exhibit 6.1-1
          The Increasing Enforcement Role in Remedial
            Investigation/Feasibility Study First Starts
     Fiscal 1987
Fiscal 1988
Fiscal 1989 (projected)
                       Enforcement
                 Fund
SOURCE: OSWER Annual R«port: Fl»eal Y>ar 1988, November 1988.
                             Exhibit 6.1-2
                Administrative Orders Issued Since the
                         Enactment of SARA
     Fiscal 1987 (Total- 100)
           Fiscal 1988 (Total" 207)
                  Removal
      RI/FS
 RD/RA
SOURCE: OSWER Annual tUport: Fiscal Y>«r 1988, Nov»mb«r 1988.
                                 87

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     6.1.4  Interaction with the Department of Justice

     In cases  where  PRPs have not  negotiated a  settlement  to clean up  their
sites, EPA's attorneys and enforcement staff, working with the Department  of
Justice (DOJ), can bring legal action against the  PRPs.   EPA refers cases  to
DOJ,  which  pursues  judicial  actions  to compel  private party clean up  under
section 106 of CERCLA, or actions for cost recovery under  section  107.

     EPA,  through DOJ, may ask a  federal  district court to require  the PRP  to
respond to any threat posed by a site.  The court also may agree to  enter into
a "consent decree" based upon successful negotiations between  EPA  and the PRP.
A consent  decree  will provide for a clean-up action managed  by the PRP with long-
term EPA oversight.   EPA also has the option, as  noted, to first use Superfund
money and  then to recover clean-up costs from the PRP.   Under CERCLA,  courts can
hold certain past and present owners and operators of  a site,  as well as  waste
generators  and transporters  and  those who  arrange for disposal,  liable  for
complete clean-up costs.   The number  and  value of cost recovery referrals and
settlements is presented in Section 6.3.

     62 Negotiated Settlements

     In FY88,  EPA  negotiated more  settlements  than in any  prior  year of the
Superfund program.  A  total  of 97 RD/RA negotiations were begun,  resulting  in
55 settlements with  an  approximate total  value  of $320 million.    This  total
included 29 consent decrees that are worth approximately $270  million in  RD/RA
work.  PRPs signed another 19 consent  decrees for RD/RA that are in the process
of government concurrence.  The value of the response  is yet to be determined.
Also, there were  seven sites where the Agency issued a unilateral administrative
order for RD/RA which resulted in settlements worth approximately  $50 million.
The 29 consent decrees lodged represents a 300 percent  increase over the number
of decrees  lodged in  FY87.   There were 50 PRP-lead RODs in FY88,  and of  these
81 percent resulted in settlement agreements.  Those settlements with response
costs of  less  than  $30 million were delegated to the  Regions.  EPA expects a
record number of RD/RA settlements in FY89 because a large number of RODs signed
in the fourth quarter of FY88 were  for sites where  settlements were  expected.

     In  addition,  EPA  negotiated  RI/FS  settlements   at   77   sites   worth
approximately  $85 million and  removal  settlements   at   94   sites  valued  at
approximately $67 million.  The,se  settlements are  for first or subsequent starts
or for takeover  of a project  the Agency has started.   Exhibits 6.2-1 and 6.2-2
summarize the  settlements  reached in FY88 and  the approximate value  of  these
settlements.

     6.2.1  Major Settlements in Fiscal 1988

     A number of major settlements were reached  during FY88. These settlements
were  significant in  terms  of the  large dollar amounts recovered and,  for some
cases, the agreement of the PRPs to  conduct a remedy. Among the most: significant
settlements are  the following:

      •    Tybouts Corner Landfill  (Delaware):   This  site is  ranked
          number 2 on the NPL and has  been designated by the State  of
          Delaware as a  top priority site.  After nearly two years  of


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               Progress Toward Implementing Superfund: Fiscal Year 1988
                                 Exhibit 6.2-1
               Number and Value of Superfund Settlements
                               in Fiscal 1988
         77
    ($85 Million)
                55
             ($320 Million)
                                                         Removal

                                                         RI/FS

                                                         RD/RA
SOURCE: OSWER Annual Report: Fiscal Year 1988,  November 1988.
                                 Exhibit 6.2-2
                Number and Value of Superfund Settlements,
                      Fiscal 1980 Through Fiscal 1988
          300
        »250
        **
        o
        i 200
        w
          150
        "o
        o 100
        Z  50
94
                       170
              77
                                     166
                                                    85
                     Removal
             RI/FS
RD/RA
           Fiscal 1988       Total- 226 (worth approximately $120 million)
     I    |  Fiscal 1980-1987  Total» 421 (worth approximately $626 million)
tOURCE: OSWER Annual Report: Fltcal Year 1988, November 1988.
                                   89

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       Progress Toward Implementing Superfund:  Fiscal Year 1988
negotiations between the Government  and PRPs to resolve a
lawsuit  filed  in   1980,   EPA  reached  a  mixed-funding
settlement under which seven PRPs will conduct private RD/RA
operations.  The remedy selected by EPA in a ROD  dated March
6,  1986,  has  an  estimated  cost  of  between $20  and  $60
million.    The   terms   of  the   settlement  require  the
signatories to contribute a total of 93 percent of the costs
of  the  remedy.   EPA is also reviewing four  de  minimis
consent decrees executed by fourteen  third party defendants
in  the  case.   When finalized, the  de minimis   settlements
will generate approximately $1.73 million.

Cannon  Engineering   Corp.   (CEC)    (New   Hampshire   and
Massachusetts): On August 3, 1988, two consent decrees were
lodged  to  settle  the  Cannon  Engineering  case.    The
comprehensive settlement, combined with earlier de minimis
settlements and administrative orders,  will result in the
recovery of $48.1  million of the  total $58.5 expected to be
incurred at the four sites.   The  settlement calls  for the
PRPs to conduct the remaining response actions  at three of
the  sites  (two RDs/RAs  and  one  removal  action),  with an
estimated total value of $16.1 million.   PRPs will also pay
approximately  $17.1  million in past  costs  and settlement
premiums connected with  the fourth site  in the case.   In
addition,   the  comprehensive  settlement accompanies  two
earlier de minimis settlements which are expected to recover
$13.4 million.  Also, three previous  administrative orders
have  been  negotiated  with  various  PRPs   in  the  case,
resulting  in  the  performance of  $1.5 million  on response
actions at three of the sites.

Seymour Recycling Corp.  (Indiana):   On  August 17,  1988,
after nearly  ten  years  of litigation, the  U.S.  lodged a
consent decree  requiring the settlors to perform remedial
actions at the  site  at  an  estimated cost of between $15.5
and $18 million.  In addition, the settlors will reimburse
the government for $6.5 of its $9.3 million  in  past costs;
this will  be  offset  by approximately $6.5  million in the
Seymour settlement trust  fund which is comprised  of proceeds
from a previous cashout settlement.

U.S. v.  Smith International  (California):   In the first
CERCLA case in which the United  States has settled with a
bankrupt generator of hazardous  wastes for future cleanup
costs, EPA reached a settlement in the Smith International
bankruptcy proceeding at the Region 9  Operating  Industries,
Inc. Landfill.   This settlement  provides for  an initial,
immediate payment of  $100,350 and a total of $5 million over
time.  EPA had originally filed a proof of  claim regarding
Smith's liability for waste clean-up  costs at several other
sites as well.
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       Progress Toward Implementing Superlund:  Fiscal Year 1988
Rocky Mountain Arsenal  (Colorado):  On February  1, 1988,  a
consent  decree  was  signed by  the  Army,  EPA,  and the
Department of the Interior,  the Agency for  Toxic  Substances
and  Disease  Registry, DOJ,  and  Shell Oil  Company.   This
decree, resolving a 1983 civil action between the Army and
Shell,  requires  the  performance  of  13  interim response
actions, an RI/FS,  and a remedy.   The  estimated cost  of the
entire cleanup is between $750 million and  $1 billion.

U.S. v. Conservation Chemical Company  (Missouri):  This  is
one  of  the  longest running hazardous  waste cases in U.S.
history, initiated in 1980 under RCRA Section 7003 and later
amended to include CERCLA sections 106 and  107 actions.   A
consent decree was  approved in April  1988 to settle this
case, with the overall cost  of  site remediation expected  to
be over $20 million.  The consent  decree approved in court
requires the original waste generators, with contributions
from the site owner/operator, to remediate  the site  and  to
provide over  $2.1  million  in  reimbursement  to  the  Trust
Fund.

Tysons Dump (Pennsylvania):   A settlement was reached with
the four PRPs  responsible for waste at the  Tysons  Dump site.
The  amended  final  ROD describing  the  remedial  design was
signed in March 1988.  This settlement included an agreement
for the PRPs to conduct remedial actions at the  site, with
an estimated total value of $10.2 million.   In addition, the
PRPs also agreed to  fully  reimburse  costs  incurred  during
an initial removal action at the site in January 1983, and
pay  all  oversight  costs at  the  site  during  the remedial
action phase.

Renora  Site  (New Jersey):   A  consent decree was  lodged
requiring  the PRPs  to  conduct  the  remedial design and
remedial action at  the site.  I-t also recovers past federal
and  state response  costs.   The consent decree  contains  a.
convenant not to  sue for the phase  of the cleanup involving
bioremediation, contingent on the determination of whether
bioremediation is a permanent remedy.  If the treatability
study does  not prove  that  bioremediation  is  a  permanent
remedy, EPA will reopen  the  Record of Decision (ROD).   In
addition,   the   government   plans  to  issue  unilateral
administrative  orders  pursuant   to  CERCLA  section  106
requiring all nonsettling PRPs to comply with the provisions
of the settlement.

Anaconda Smelter (Montana):   Pursuant to an administrative
order  on  consent  under Section  106  of  CERCLA,  the PRP
conducted an expedited RI/FS at  the  Mill  Creek site, part
of the larger Anaconda Smelter  complex.  The interim  remedy
selected in the  ROD,  dated October 2, 1987,  is  permanent
relocation of residents, demolition of houses, and temporary
site  stabilization.    The  PRP is  responsible,   under the

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


          lodged consent decree,  for costs incurred by the federal and
          state governments in implementing the interim  remedy.  The
          Agency reserves the right to conduct further investigation
          and  CERCLA  response  actions  at  the  Mill  Creek site,
          including a permanent remedy.

     Since the  passage of SARA,  EPA  has  developed a  number  of mechanisms  to
facilitate and  expedite  the  settlement process.   These  include special notice
letters, arbitration,  de minimis  settlements,  covenants  not to sue, and mixed
funding settlements.  Each of these mechanisms is discussed in turn below.

     622  Notice Procedures

     Notice  procedures  help  expedite  the enforcement  process  by promoting
negotiations between EPA and  private  parties.   The Agency uses notice letters
to inform PRPs of their potential liability and to offer  them  an opportunity  to
enter into negotiations  about conducting  response activities.  Notice letters
also serve to initiate  the exchange of information which is vital  to enforcement
negotiations.   The  notice  process involves three separate steps: the general
notice, the RI/FS special notice,  and the RD/RA special notice. On February 23,
1988, EPA issued interim guidance  (53 FR 5298) on procedures for drafting notice
letters, negotiations with PRPs,  and information  exchange.

     General Notice

     EPA  issues a general notice to PRPs  to inform  them of their potential
liability for future response costs,  to promote further  information exchange,
and to initiate the process of "informal" negotiations.   Issuance of the RI/FS
special notice occurs at the  discretion of the Regions.  The decision about  when
to issue the RI/FS special notice depends  upon the nature of the  remedy and the
existence or involvement of PRPs'.

     The RI/FS  special notice generally is  sent to a PRP no later than 90  days
prior to the scheduled start of the RI/FS.   This procedure invokes a moratorium
on EPA's RI/FS  activities  and triggers a  period of formal negotiation.  Until
the  conclusion  of  these RI/FS  activities,  the  Region  actively  manages the
negotiation process by  transferring information to the PRPs.

     Special Notices

     The RD/RA special notice begins a period for formal negotiation and invokes
a 60-day moratorium on  EPA's activities.  OSWER has established three  approaches
for  issuing  the RD/RA  special notice  (in order  of  preference):   issuing the
special notice  when the  draft FS  and the proposed plan are released  for public
comment, issuing the special notice prior  to the release  of the draft FS and the
proposed  plan,  or issuing  the  special notice  after the  ROD is signed  (this
requires a waiver from EPA Headquarters).   The idea behind these  approaches  is
to ensure  EPA's ability to  conduct meaningful negotiations,  to maintain the
integrity of the public's participation, and to minimize delays in implementing
the RD/RA.

     For  60  days after  the special notice  is issued,  EPA  formally  negotiates
with PRPs  about taking over  the  RD/RA.  EPA will discontinue  negotiations and

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


either issue a unilateral administrative order,  or begin a fund-lead cleanup  if
it does not receive a good faith offer at the end of the 60-day moratorium.   If
EPA receives a good faith offer from PRPs, the moratorium period may be  extended
to a total of 120 days  (or more).

     Historically, RD/RA activities have  been delayed due to extension of the
negotiating period  past the moratorium deadline,  issuance of special notices
much  later  than  the  ROD,  and  a lack  of resources  in certain  Regions.    An
analysis performed  by the  Office of  Waste  Programs Enforcement  (OWPE) showed
that for sites where the special notice is not issued until after the remedy  is
selected, RD/RA negotiations  continued  an average of 70 days past  the initial
60 day moratorium.

     EPA  has  issued  recommendations  for  improving  and  expediting notice
procedures in order to reduce delays  they have caused  in  the  remedial  process.
In addition, EPA has provided guidelines for  the Regions  to  follow  in  managing
the enforcement negotiation process.   Emphasis  has been placed on  cutting off
negotiations after  the  first  60 days when PRPs  do not make a definitive good
faith offer.  To prevent PRPs from exceeding  the deadline, EPA will extend the
total 120-day moratorium only rarely.  Also, Regions  have placed  emphasis  on
issuing  special notices in a timely  manner,  either with the proposed plan  or
within a week of the signing of  the ROD.

     623 Arbitration

     Under CERCLA section 122(h)(2),  as amended by SARA,  the  Administrator (or
the head of any other  department or agency authorized to undertake  a  response
action under CERCLA) may use arbitration as a means of  settling certain section
107  cost-recovery  claims.    Arbitration  may  be  used  in  accordance  with
regulations promulgated by EPA,  or other  authorized agencies or departments,
after consultation with the U.S. Attorney General.

     On  August  4,   1988,  a  proposed  regulation  providing  EPA  arbitration
procedures for small Superfund cost recovery claims was published in the Federal
Register for public  comment.   This  regulation,  when finalized, will implement
CERCLA section 122(h)(2), which  authorizes  EPA to use arbitration  as  a method
of settling section  107  cost  recovery claims when the total  response  costs  at
the site do not exceed $500,000  (excluding interest).

     6.2.4 De Minimis Settlements

     During  FY88,  there  were  12   settlements   which   involved  de  minimis
contributors  of  waste  as  a  group.    In  these  settlements, the  de  minimis
component was worth about $16 million, or 13 percent of the total site  costs  of
$129 million.

     De minimis settlements involve  parties that contributed very small amounts
of hazardous waste  at a site.  At some  Superfund sites there are  hundreds  of
PRPs; EPA therefore, can reduce the  number of parties involved by settling with
de minimis  contributors as  a group.  As a result, the Agency conserves resources
that might be expended in lengthy negotiations,  and de  minimis parties  are able
to end their involvement more  quickly.   Negotiations with other  PRPs  are thus
made more manageable.


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     CERCLA 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.  Section
122(g)  includes  two  types  of de  minimis  parties:   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,  or acquired the property
without knowledge of  contamination.  In addition,  the landowner must not have
contributed to the release or threatened release at the facility.

     Settlements may  be embodied  in a  consent decree or administrative order,
and de minimis settlors may be provided with a covenant  not to  sue.  De minimis
settlors also are entitled to contribution  protection.   Contribution protection
shields settlors from being held  liable for more than their rightful share of
cleanup costs.  On November 12, 1987, EPA published draft language (52 FR 43393)
for drafting de minimis waste contributor administrative orders  on consent and
consent decrees.

     6.2.5  Covenants Not To Sue

     A covenant not to sue excludes a  PRP  from liability to the United States
under  CERCLA,  including  future  liability,  that results  from a  release  or  a
threatened release  addressed by a remedial action,  thus  encouraging a PRP to
reach an early settlement.  These  agreements generally include  "reopeners" that
allow  EPA to  hold  PRPs  liable  for  conditions unknown  at  the time  of the
settlement, or if new information indicating that  the  remedial action is not
protective of human health and  the environment.   In some settlements, such as
de minimis settlements, covenants may be granted without reopeners.

     CERCLA Section 122 (f)(l) authorizes EPA to issue a covenant not to sue if:

          •    The covenant is in  the public interest;
          •    It would expedite the response;
          •    The settlor is in full  compliance with a section
               106  consent   decree addressing  the  release  or
               threatened release; and
          •    EPA has approved the response action.

     62.6  Mixed Funding

     During FY88, EPA approved two mixed funding settlements,  one preauthorized
and one for mixed work.  In  addition,  a third  mixed funding settlement is  still
in litigation  and has not yet been lodged.  Under the terms of each of  these
settlements, the PRPs were required to contribute over half of  the  total cost
incurred  at  the respective  sites.   The two  finalized and  one pending  mixed
funding settlements were:

     •    McAdoo  Associates  (Pennsylvania):    In  June,   1988,  a
          preauthorized mixed funding settlement was  entered  into


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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


          between  EPA and  69 of  the  93  PRPs at  the McAdoo-Kline
          Township Superfund site.   The settlement calls for the  PRPs
          to conduct  the  RD/RA,  which  has  an  estimated value of $3
          million.  Of  this  amount,  the PRPs are responsible for 75
          percent, or  $2.25  million under  the settlement, with the
          remaining  25  percent  preauthorized.   The  PRPs  are  also
          required to pay for $793,000 of $993,000 in past  costs at
          the site, as well as 75 percent of future costs.

     •    Ottati  and Goss  (Kingston  Steel Drum)  (New Hampshire):
          Under the terms of this mixed work settlement,  the PRPs are
          to perform  60 percent  of the RD/RA  work at the  site; EPA
          will perform  40 percent.   The cost of the remedy  is $11.6
          million.  This settlement, however,  had not  been lodged as
          of May 1989.  The underlying  enforcement case is  currently
          in litigation.

     •    Harvey and  Knott  Drum, Inc.  (Delaware):   A mixed  funding
          settlement was reached during October, 1987.  The PRPs are
          to perform the entire RD/RA work at the  site; 67  percent of
          these costs are to  be  paid by PRPs,  with the remaining 33
          percent having been preauthorized;  the  estimated value of
          the remedy is $10.4 million.   In addition, future oversight
          costs and  $1  million of  past costs  at  the  site are to be
          paid by  PRPs.   The RD is an ongoing process,  and RA  work
          began in January 1988.

     Mixed funding, authorized by CERCLA section 122(b), occurs  when  Superfund
and  PRP  funds are  used jointly to finance  cleanup   efforts  at a site.   To
determine if mixed funding is  appropriate at a site, EPA evaluates both the most
effective means of cleanup and the most  effective use of the Agency's resources.
Use of mixed funding is most  likely to  be approved at  sites  where some parties
are  willing  to  settle  and  to  conduct the  cleanup,  and  where  there  are
financially solvent nonsettlors that EPA may pursue.   Money from  Superfund will
not be provided,  however,  until the cleanup  has been completed.  PRPs who  settle
in a mixed funding agreement must pay 100 percent  of  the clean-up costs,  before
the initiation of the cleanup process.

     When the  cleanup  is finished  and  certified  as  done  properly,  EPA will
reimburse the settling  parties for  that portion of the costs specified  in the
settlement agreement.  The Agency,  meanwhile,  sues the parties that refused to
settle in order  to recover  the  federal share of the clean-up  costs.   Mixed
funding thus permits cleanups  to proceed even in  cases where some of the PRPs
refuse to settle out of court.   On  March 14,  1988, EPA issued guidance  (53 FR
8279)  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."

     62.7  Nonbinding Allocations of Responsibility

     On  March  4,  1988,  Region   1   proposed  a  Nonbinding  Allocation  of
Responsibility (NEAR) for use in the RD/RA  special notice  negotiations for the

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Re-Solve site  in North Dartmouth,  Massachusetts, among  the approximately  320
PRPs at the site.  This is  the  first NEAR  issued.  An NEAR was prepared  in this
case because of a dispute among the PRPs as to how to allocate  cleanup  costs  for
PCBs.  Negotiations based on the NEAR resulted in an agreement in principle in
September 1988.  Under this  settlement, the  government  is expected to  recover
$9.2 million in  past costs spent at the site and receive $23.3 million toward
future cleanup efforts.

     NBARs are a means  by  which EPA allocates the total response costs among
PRPs at a site.   EPA sends NBARs to PRPs  at  the  PRP's request, informing them
of the percentage of total  site response costs  for which  they  are determined to
be responsible.  The NEAR,  however,  is not a statement of damage or liability,
nor is  it  admissible  in court as evidence.   The major  factors  considered in
determining response cost allocations include the  volume,  toxicity, and mobility
of waste contributed by a PRP,  and the nature of the  evidence against  various
PRPs.

     Under  current Superfund  policy,  PRPs  are  expected  to  determine among
themselves the exact allocation of each portion  of the  cleanup cost.    EPA  may
step in  and issue NBARs (normally during the RI/FS.)  to prevent: .conflict  and
delays and to promote  a settlement.  After receiving an NEAR,  PRPs may offer to
undertake or finance a cleanup; they are still expected  to determine  the final
allocation of cleanup costs among themselves.

     63   The Cost Recovery Program Under CERCLA Section 107

     Progress in Fiscal 1988

     The total amount  recovered by the Agency in  FY88 cost recovery settlements
was greater than that in previous years.  A total  of $55.6 million was  recovered
at  121  sites,  as  compared to  the  $36 million recovered in  FY87  and  the  $17
million recovered in FY86.  This is a 65 percent  increase over  the total amount
recovered during the past  fiscal year,  and  represents 40 percent of the $139
million recovered  since  the  start of  the Superfund  program  (Exhibit  6.3-1).
Also, a total  of 56 cases with a combined value  of  $120 million were referred
to EPA Headquarters from the  Regions in FY88.  This total is nearly double that
of  the  37  cases  (with  a total value of $66  million)  referred to Headquarters
from  FY81  through FY87  (Exhibit  6.3-2).    In  addition,  59  cases with   an
approximate total value of $27 million were referred to DOJ under CERCLA  Section
107, and 50 civil actions were  filed by DOJ,  with an approximate  total value of
$19 million. A comparison of cost recovery data from FY88 to cost recovery data
from all prior years of the Superfund program  is presented in Exhibit 6.3-3.

     Background

     The purpose of the cost recovery program is to seek reimbursement  from PRPs
for  cleanup costs incurred  by the  government  at   waste  sites.    Prior   to
initiation of the RI/FS by the Agency,  parties identified as being potentially
responsible for  the threat  posed by a site are  given the  opportunity to  perform
the  RI/FS.   PRPs are  also  given the  opportunity to   conduct  any  immediate
response  actions  as  well  as  remedial  actions  determined  necessary  at  the
conclusion  of   the  RI/FS.     The  PRPs,   which  may  include  generators   and
transporters of  the hazardous substances  involved in the release, as  well as


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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   Exhibit 63-1
           Value of Cost Recovery Settlements By Fiscal  Year
Fiscal Year
1988
1987
1986
1985
1984
1983
1982
1981
Total
Total Dollars Recovered
$ 55,600,000
35,755,000
17,300,000
18,000,000
7,000,000
2,000,000
3,000,000
250,000
$138,905,000
SOURCE:
          The Superfund Progress Report as of September 30. 1988. OSWER, December 29, 1988.
                                    Exhibit 6.3-2
               Number and Value of Cost Recovery Referrals
                              to EPA Headquarters
                                                  Fiscal 1988
                                                  Fiscal 1980-1987
                                                Program-to-Date
                                        Total Cost Recovery Referrals = 93
                                   Total Value of Referrals = $186 Million dollars
      SOURCE: OSWER Annual Report: Flteal Y»ar 1988, Nov»mb»r 1988.
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                                   Exhibit 63-3
                          Cost Recovery Activities
     Civil Actions
                              FY 1988
 Prior to
 FY1988
Totals
     Referred to EPA HQ
       from the Regions
                              56
 93
149
     $ Value of these  actions     120  million

                                   59
Referred to DOJ under
  CERCLA Section  107

$ Value of these  actions

Civil Actions Filed by  DOJ

$ Value of these  actions

Reimbursement to  the
  Trust Fund
186 million     306  million

252             311
                                   27  million

                                   50

                                   19  million

                                  101  million
285 million

221

274 million

180 million
312 million

271

293 million

291 million
     NOTE: Values listed for settlements include accounts receivable, not just amounts collected.

     SOURCE:  The Superfund Progress Report as of September 30. 1988. OSWER, December 29, 1988.
current and former owners or operators of  the  site  and parties who arranged for
disposal, must agree to reimburse EPA for  the  cost  of the  Agency's oversight if
the PRPs  agree to conduct  the RI/FS.    Under  CERCLA  section 104, EPA  has the
power to initiate response actions at a  site without  delay,  pending the outcome
of legal action.  These response costs are recoverable from PRPs by the Agency.

     Section  107  imposes two  principal  types  of liability on  PRPs:  joint and
several liability (where the harm is indivisible),  and strict liability.  Under
joint and several liability, all PRPs can be sued jointly or any one can be sued
separately for 100 percent  of the  clean-up costs for  a site.   Strict liability
does  not require  that EPA  demonstrate  that  a  PRP   was  at  fault.    EPA must
demonstrate only that  the harm at the site was caused by a substance similar to
that  produced by  the  generator,   and   that  some  of  a generator's  hazardous
substances came to be located at the  site.  The Agency  does not have to establish
that the generator acted willfully or negligently.

     Cost Recovery Program Guidance Documents

     In  order to implement the cost  recovery program more  aggressively, EPA
issued two guidance  documents in FY88.   The first, entitled The Superfund Cost
Recovery Strategy (OSWER Directive 9832.13, July 29, 1988), provides a framework
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for planning and initiating actions to recover  federal funds  expended by EPA or
a  state  during  CERCLA  response actions.   The  second,  entitled  Guidance on
Documenting Decisions Not to Take Cost Recovery Actions (OSWER Directive 9832.11,
June  7,  1988),  discusses  the  information to  be  included  in  EPA close-out
memoranda written  to document  the  basis  of EPA  decisions  when  recovery of
unreimbursed Superfund monies is not being sought.

     EPA also delegated concurrence  on most  section 107  cost recovery actions
to the Regions on June 17,  1988  (OSWER Directive 9012.10-a).  As a result, EPA
Regional offices now have a greater amount of authority to resolve section 107
claims without  approval  from EPA  Headquarters;  referrals subject  to  the new
criteria for delegating cases to the Department of Justice may now be referred
there directly by Regional offices.

     The Superfund Cost Recovery Strategy encourages  the Regions to  seek cost-
recovery settlements under  section 122(h)  to  speed  up  the process and to reduce
costs to the government.   For settlements  of less  than $500,000, EPA does not
need to obtain approval from the Attorney General.   For those cases where there
is no settlement, the Region is  to  consider seven primary factors when deciding
which cases to prosecute:

     •    The dollar amount involved;
     •    The strength of the case against the PRP;
     •    The possible defenses;
     •    The quality of information about a site;
     •    The ability of the party to pay;
     •    The statute itself; and
     •    Other cases on the government's docket.

     If, after  a review of  a case on the basis  of  these  factors  the Region
decides not to pursue a cost recovery action,  the decision is  recorded in a cost
recovery close-out  memorandum.   Regions  are  encouraged to  develop  cases for
litigation for all  sites where  response costs  are  greater than $200,000 and a
negotiated settlement was unsuccessful.   Cases  where  response costs were less
than $200,000 are less likely to be selected  for litigation unless the PRPs are
recalcitrant, evidence linking  them to the site is good,  and  the  case may be
used to create a good precedent or is otherwise meritorious.

     For emergency  cleanups,  cost  recovery actions should be  referred to the
Justice Department as soon as possible after completion of cleanup activities,
or for most cases,  not later  than  one year after completion.  Referral should
occur at the time of initiation of physical  on-site construction.    EPA should
seek to recover costs at all sites where an emergency cleanup was carried out,
regardless of whether the site is on the NPL and whether further response action
is to be taken.

     This strategy sets priorities for EPA Regions  in determining the sites at
which it should  seek the  recovery of cleanup costs.   The  highest  priority is
placed on recovering costs  at  all sites where a remedial action has taken place.
Next in priority are sites involving expenditures of over  $200,000 for emergency
cleanups, and where the statutes of limitations presents a problem.  The third
priority is also placed on sites that involve expenditures of over $200,000 on
emergency cleanups,  but where the statute  of  limitations  is not a problem.  The

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fourth priority goes to  sites were EPA has obtained a partial settlement for less
than the full cost of cleanup and where there are financially sound PRPs who did
not participate  in the  settlement.   Finally,  the lowest priority  covers  those
sites where  total  cleanup  costs  are  less  than $200,000 and the government has
a strong case against recalcitrant parties.

     The Agency also will attempt to extend cost recovery efforts to cases  where
cost recovery suits against polluters  appear  to be prevented by expiration of
the statute of limitations.  Under SARA section 113(g), the federal, government
cannot sue a PRP for the recovery of cleanup costs more than  three years  after
the completion of  a removal or more  than  six  years after the start of on-site
work for remedial  action cleanups.   EPA interprets the statute of limitations
to apply only to cleanups  begun  after  SARA was signed into law on October 17,
1986;  the  Regions, however,  are  instructed to  refer cases  whether or not  a
cleanup action was initiated before SARA became law.

     6.4 Orders Under CERCLA Section 109 for CERCLA Section 103 Violations

     The first civil administrative  complaint  under section  109 of CERCLA for
a section 103 violation, and under section 325(b)  of the Emergency  Planning and
Community Right-to-Know Act of 1986 (SARA Title III),  was  issued by Region I on
September 30, 1988.  In this case,  the  Region  alleged that All Regions Chemical
Lab, Inc. ,  of Springfield, Massachusetts, had violated both section 103 of CERCLA
and section  304  of Title  III, in its  failure  to  notify the  National Response
Center of a  release, and in its  failure to provide a written follow-up notice
to  the state emergency planning  commission and  the  local emergency planning
committee.   Region I,   therefore,  assessed  a civil  penalty of $25,000  for the
section 103 violation,  and a penalty of $25,000 for the first day  of the  Title
304 violation and  $500  per day afterwards until the required  notice is filed.

     Under section 109  of CERCLA, a civil penalty not exceeding $25,000 may be
assessed  against  a  generator  of  a  hazardous  substance  who  violates  the
notification  requirements of CERCLA section 103(a)  or (b)  for the  release of a
hazardous substance.   In addition,  for each day such a violation  continues,  a
civil penalty not exceeding $25,000 per day may be assessed against the violator.
Action may be also brought  in  a United States district court to assess a penalty
of not more than $25,000 per day for each day the violation, failure, or refusal
continues.   If there is a second or subsequent  violation of the  section 103
notification  requirements,  a penalty  not  to  exceed $75,000 per  day may be
assessed against  the person for each day the violation continues.

     6.5 National Enforcement Investigations Center Activities

     The National  Enforcement Investigations Center (NEIC),  located in Denver,
Colorado, provided important  support to EPA during FY88  in responding to both
civil  and criminal CERCLA investigations.   In the area of  technical support for
judicial enforcement of Superfund cases, the NEIC was involved  in the development
of  13  new  civil  cases  and  continued to support the development  of 26 criminal
Superfund  cases.   Also, within the  NEIC's Criminal  Investigation Program, 55
investigations were conducted of cases involving some CERCLA activity, and four
of  these cases involved CERCLA alone.
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     In addition to providing civil and criminal  litigation support for CERCLA
investigations,  the  NEIC also provides  support in the area  of  EPA and state
regulatory programs  for air, water,  toxics,  pesticides,  radiation,  and solid
wastes pollution control.   The NEIC  works  in coordination with the Assistant
Administrator for Enforcement, the General Counsel,  Regional offices, and other
EPA Program Directors and their staffs in case preparation in all program areas.
To manage EPA's criminal investigations on a national  basis, the NEIC maintains
an expert staff of criminal  investigators,  and  provides technical training for
criminal  investigation activities  in all  regional offices.   Also,  the  NEIC
provides  guidance  and expertise  to  the Office of  Enforcement and Compliance
Monitoring (OECM)  for the development  of  enforcement strategies  and evidence
management, and  to  Headquarters,  EPA Regional  offices,  and  the Department of
Justice for the monitoring of technology and  remedial  programs.

     The primary responsibilities of  the NEIC include:

     •    Assuring that scientific and  technical  evidence  is
          adequate and valid; this includes data  collection and
          analyses and the review and development of  analytical
          techniques, methodologies,  and computer information
          systems;

     •    Providing services to assist  quick  response  by EPA in
          emergency situations;

     •    Applying enforcement strategies in  coordination with OECM
          and the Regional Counsels;

     •    Providing consultation and  assistance in case preparation
          activities;

     •    Providing management, training, and other specialized
          assistance to the Regional  offices  on criminal
          investigation; and

     •    Providing expert testimony  on a wide variety of
          specialized subjects in support of  enforcement.

     In addition, the NEIC works with staffs  of other  Assistant Administrators
to prepare, assemble, and analyze  scientific and technical  data.  The NEIC also
coordinates with staffs  of Regional Administrators   to  provide  support  and
training  for   federal,   state,  and   local  personnel,  and works  with  other
government agencies  also  involved with civil and criminal case preparations.
To assist  in  these  efforts,  the NEIC  produces  reports,  guidance,  and other
publications.
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7.0   THE EPA PARTNERSHIP WITH STATES AND INDIAN TRIBES

     7.1  Overview

     CERCLA, as  amended,  includes provisions for greater: state  involvement in
Superfund response and decision-making  activities.   SARA emphasizes  the CERCLA
provisions  concerning   state  involvement   by  requiring  "substantial   and
meaningful" state  involvement  in  all phases of Superfund response activities.
CERCLA extends the opportunity for involvement to Indian tribes, which are to
be treated substantively the same  as  states  for most purposes.

     12  State Involvement Regulations

     Section 121(f)(l)  of CERCLA  requires  the  President (delegated to  EPA in
Executive Order 12580) to promulgate regulations providing for  the  "substantial
and  meaningful"  participation  of   states   in pre-remedial,   remedial,   and
enforcement response  activities.   In fiscal year 1988,  to meet  this  statutory
requirement and  to strengthen  the EPA/state partnership, the Agency  developed
Subpart  F  of the  proposed revised  NCP.  Also,  the Agency made  progress  in
developing procedures under section lll(o) to notify state and local governments
of limitations on response claims.

     72.1 State Involvement Under the Proposed Revised National Contingency Plan

     The proposed revised NCP was published in the Federal Register on December
21, 1988.  Proposed  Subpart  F  is  completely new and  codifies in one  place  all
regulatory requirements  for state participation  and involvement in  Superfund
response activities.   In  general, these proposed revisions to  the NCP will
broaden  the  opportunity  for  state  involvement  by  implementing   the SARA
requirements  and by encouraging  state participation   in  Superfund  response
activities beyond the minimum  statutory requirements.

     Proposed  Subpart F  discusses  the roles  of  EPA  and  the  states  in  the
selection of  remedy  process.   This  discussion reflects  the  evolution of  the
EPA/State partnership  in  recent years by assigning  the state,  when it  is  the
lead agency, responsibilities  in  remedial  process activities that lead to  the
selection of a remedy.   The state as lead  agency may recommend the  remedy to
EPA.   This new concept would be applicable to both Fund-financed and  non-Fund-
financed actions (e.g., enforcement  actions).

     The  concept of  a state-recommended  remedy  is  designed to  further  the
EPA/state partnership, optimize the use  of  governmental  resources,  and increase
the number  of  response actions.   Under the  current  NCP,  EPA has significant
involvement in and oversight  of activities  at  state-lead Fund-financed sites.
Conversely, EPA has limited involvement at state-lead non-Fund-financed sites.
States currently have limited responsibilities during  selection of remedy  at
EPA-lead sites.

     CERCLA requires EPA to attain state ARARs that are promulgated and are more
stringent than federal ARARs.   Proposed  Subpart  F establishes a process for lead
and  support agency  consultation  and  for   solicitation of their respective
identified ARARs and other criteria,  guidance,  and advisories to be considered
that  may  be  helpful  in  establishing protective  cleanup  levels.    This


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communication/consultation process  is  ongoing  throughout  the  remedial response
process and  should ensure that  all responses comply  with  all ARARs  and that
other  criteria,  guidance, and  advisories are  considered,  where  appropriate.
The  Agency  is   currently developing  procedural  guidance  for  federal/state
interaction on the identification of ARARs.

     Proposed section 300.510 of Subpart  F codifies the statutory provisions for
use  of credits   to  offset a  state's  required cost-share.   CERCLA  authorizes
credit for state or political subdivision expenditures or obligations for cost-
eligible response  actions taken at  NPL sites from 1978 to  1980.   From October
16, 1986 forward, CERCLA  section 104(c)(5) limits  credit  to state expenditures
for remedial actions only.  EPA  and states have reviewed  the  credit  provisions
to determine whether state or Trust Fund liabilities  existed  and found none.

     122  CERCLA Section lll(o) Notification Procedures

     Section lll(o)  of CERCLA  requires  the President  (EPA by delegation)  to
develop and implement procedures to adequately notify concerned state and local
officials and other  concerned persons  of the limitations on payment of claims
for necessary response  costs.   EPA published a notice in the  Federal Register
advising the public of  the limitations on CERCLA response claims  and providing
an adequate  opportunity  for  comment  before the Agency  adopts procedures  for
notice  pursuant to  section  lll(o) of  CERCLA  (February   5,  1987).   EPA  is
developing the section lll(o)  procedures  to notify state and local officials and
other concerned persons of the limitations on response claims and procedures for
filing claims against the Fund  (i.e.,  CERCLA section  112 procedures) and plans
to propose them  in 1989.

     73 Procedures for Involvement of State and Local Governments and Indian Tribes

     EPA has promulgated  an  interim final rule that sets forth  the  procedures
for the involvement in the Superfund program of states, political subdivisions,
and Indian tribes (40 CFR Part 35 Subpart 0).   Subpart 0  describes requirements
for  State Superfund  Contracts  (SSCs)   and  Cooperative  Agreements   (CAs)  and
establishes  support  agency cooperative  agreements  (SAGA)   for funding support
agency  activities.   Support  agency activities are activities conducted by  a
state  or  federally-recognized   Indian  tribe  pursuant to  the NCP   to  ensure
meaningful, substantial involvement when the state  is  the support agency for a
federal or political  subdivision lead  site,  or an Indian tribe  is the support
agency  for  a federal-lead site.    The SSC,  not the  SACA,  is the vehicle  for
documenting Section 104 assurances.

     73.1  Cooperative Agreements with States

     Section 104(d)(l)  of CERCLA permits EPA to transfer federal  funds and to
authorize states to undertake CERCLA response activities via a CA.  With states,
the Agency  may  enter into CAs  that:   (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.
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     For state lead Fund-financed remedial actions,  the  CA  is  also used by EPA
to obtain  the required state  cost-share  (i.e.,  10  percent)  and other  CERCLA
section 104 assurances.  In federal lead response, EPA leads the response  with
the state  acting in a  support agency  role.    For  federal lead Fund-financed
remedial actions, EPA uses  an SSC  to  obtain the  required state cost-share and
other CERCLA section 104 assurances.

     73.2 Cooperative Agreements with Local Governments

     CERCLA permits EPA to enter into  CAs  with "a ...  political subdivision" to
carry out any action under the law  if the state and  the  Agency decide  that the
local government can adequately undertake the  action.  In  accordance with  this
provision,  Subpart F of the proposed revised NCP  allows  political subdivisions
of a state to take the lead for certain response  actions via a CA.  States are
required, however, to be active partners.   A state may request  that a political
subdivision take the lead for  a remedial cleanup.  In this case, EPA, the state,
and the political subdivision  are required to  establish  a  three-party  SSC  that
sets forth roles and responsibilities  of each party during  response actions and
is amended  to add  state  section 104  assurances when the  remedial  action is
selected.  The  SSC must specify the  requirements associated with a political
subdivision lead, and such Fund-financed actions must comply with CERCLA and the
NCP.  For remedial actions, the state must underwrite  the  required section 104
assurances.

     Local authorities may be  the first to identify  a  hazardous waste  site and
bring it to the  attention of  state  and local authorities.   They often provide
valuable information  on the  site  location (site  discovery),  details on  site
history  (site  investigation) ,  and  information  on  potentially  responsible
parties.

     Currently,  there  are a  number of local  governments  acting  as the lead-
agencies for Superfund remedial actions or operable units of actions:   Dade and
Broward Counties in Florida, South Adams County in Colorado, and Lidgerwood and
Wyndmere Townships in North Dakota.   EPA will continue to seek  local government
participation in  its efforts  to  address the hazardous waste issue nationwide.
Local governments are playing an increasingly  important role  in the  Superfund
program.

     133 Core Program Cooperative Agreements

     EPA developed the core  program  cooperative agreement (CPCA) concept to  help
ensure that each state has the funds to  carry out  CERCLA activities.  CPCA funds
are intended to strengthen,  and maintain a state's ability to participate in all
aspects of the Superfund program, thus enabling it to take the lead for response
actions  at more sites  and  to participate   fully  in  CERCLA implementation
activities conducted by the Agency.

     The following functions  are eligible for  funding  under a  CPCA:

     •    General  program  management  and  supervision to support
          Superfund activities;
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     •    Superfund program interagency coordination on all phases of
          response;

     •    Legal assistance relating to  the implementation  of CERCLA;

     •    Development of procedures for  fiscal and contract  management
          to support the Superfund program; and

     •    CERCLA-related  clerical  and  administrative  support  not
          directly or  indirectly  charged to  any other  site-specific
          CA.

     CPCAs are negotiated with states and are funded annually.   Funding requests
must be  made through the Superfund Comprehensive Accomplishments Plan  (SCAP)
process.  A  state  is  required to  contribute  at least 5 percent of the cost  of
the  response program support activities covered  by the  CPCA.   CERCLA  state
credits may  not be used to  offset a state's  cost-sharing  obligation  for  CPCAs
since CERCLA authorizes the use of credits for site  response only.

     OSWER  supplemented the  Final  Guidance  on  State Core  Program Funding
Cooperative  Agreements  (December  18,  1987)  in August 1988 and promulgated  its
provisions  in  an Interim Final  Rule   (40  CFR 35  Supbart  0) .   A  total  of  36
states,  including  Puerto Rico,  entered into  or  were planning to enter into  a
CPCA in FY88.  OERR will evaluate the CPCA mechanism during FY89 and  will base
future guidance concerning CPCAs on the results  of this evaluation.

     7.4  Superfund Memoranda of Agreement

     CERCLA  section  121(f)  specifies  the minimum statutory  requirements  for
state  participation  in  Superfund response  activities.   Through the  use  of
EPA/state Superfund Memoranda of Agreement (SMOAs), the Agency  encourages  state
involvement  in the Superfund program beyond the minimum statutory requirements.
Subpart  F  of the  proposed  revised NCP introduces the  SMOA  as  a vehicle  for
establishing an  effective EPA/state working  relationship.   SMOAs are intended
to strengthen EPA/state  interaction by specifying in advance how EPA and each
state  will  carry  out  their  respective responsibilities  in  keeping  with  the
partnership  concept.

     SMOAs are intended to define and  facilitate  communications between EPA and
a  state on  all aspects  of  the  response process.    A SMOA  will  define  the
operating relationship  between EPA  and a state,  as  agreed by  the EPA Regional
office  and  the state, and  as executed by the Regional Administrator and  the
State Agency Director.  A SMOA defines the EPA/state relationship  by specifying:

     •    Interaction during  response  activities;
     •    Procedures and timeframes  for consultation  on planning activities;  and
     •    EPA oversight.

     7.5  State Assurance of Capacity

     Under  section 104(c)(9)  of CERCLA, every state  either must, assure  EPA no
later  than October 17, 1989,  that there will  be adequate capacity (in  or  out of
state)  for  the  treatment or disposal  of all hazardous  wastes  generated  within


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the state over the next 20 years, or the agency may not provide Superfund monies
for remedial  actions  in the  state.   During FY88,  the Agency,  along with  the
National Governors' Association (NGA),  developed draft guidance to assist states
in meeting  the hazardous waste management  capacity assurance requirements of
section  104(c)(9).   The Agency  published this draft  guidance  in the  Federal
Register on August 31,  1988,  and requested public  comment.

     Four work groups created by NGA under a $1.2  million  CA  with EPA produced
the draft guidance on state assurance of capacity.   These work groups consisted
of representatives from  EPA, state  and  local government agencies,  industry
associations,  and public interest  groups.   The draft guidance  would  require
states to prepare a capacity assurance plan  (CAP) to comply with the  section
104(c)(9) requirements.

     The draft guidance  is broken into  four parts:

     •    Current state-specific hazardous waste data and projections
          for  the  future;

     •    Allowances  for using  waste minimization  programs  to cut
          hazardous waste volume;
     •    Plans for developing new treatment capacity;  and

     •    Interstate agreements  for  treating these wastes.
     The  Agency  and the  NGA  workgroups reached agreement  on the first  three
parts of  the  draft guidance,  but did  not  reach a  consensus on the  interstate
agreement  component.   Consequently,  in  the  published  draft  guidance,  EPA
presented and solicited comments on both NGA's  final  recommendations and  on an
alternative set of recommendations for the development of  interstate  agreements
regarding waste exports and imports.   In general, the states want  EPA to assume
greater responsibility for resolving differences between states  over  interstate
export and import of wastes, whereas  the Agency believes that the  states should
resolve such conflicts among  themselves.

     EPA anticipates that the  draft guidance on  state assurance of  capacity will
be finalized during  1989.

     7.6  Indian Tribes

     CERCLA  requires EPA  to  afford to  Indian  tribes  substantially the same
treatment  as it  would  to states  regarding  their   involvement  in Superfund
response activities.  Subpart F of the proposed revised NCP does  differentiate
between states and Indian tribes  with  respect to CAs.  An  Indian tribe may be
authorized  to undertake  the  lead  for  Fund-financed  response  activities  or
authorized activities as  a  support agency  via a CA or SACA  if:

     •    The Indian tribe  is federally recognized;

     •    The   tribal   governing  body   is   currently  performing
          governmental functions  to  promote the health,  safety,  and
          welfare  of its  affected population  or environment;  and

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     •    The Indian  tribe  can demonstrate that the  functions  to be
          performed are within  the  scope of its jurisdiction.

     7.6.1  Applicability of State Participation Regulations to Indian Tribes

     The definition of "state" in Subpart A of the proposed revised NCP includes
Indian tribes and, therefore, unless  specified otherwise,  federally-recognized
Indian tribes generally may have  the  same roles and responsibilities under the
NCP as do states.

     Proposed Subpart F also provides  for Agency interaction  with  federally-
recognized Indian tribes when an NPL site is on Indian lands.  For these sites,
a separate  SMOA may  be  developed,  and  in some  instances,  the SMOA may  be  a
three-party agreement between EPA, a state, and the federally-recognized Indian
tribe.  Federally-recognized Indian tribes do not have to provide CERCLA section
104(c)(3) assurances  (i.e.,  assurance  of future  maintenance,  cost-share,  and
availability of a hazardous waste disposal facility).

     7.62    Cooperative Agreements with Indian Tribes

     EPA Region 6  and the  Navajo Nation began negotiating a number  of CAs and
SMOAs in FY88.  These agreements  include:

     •    A core program  cooperative agreement to  support  the  newly
          established Navajo  Superfund  Office;

     •    A  multi-site  CA  for  preliminary  assessments  and  site
          inspections at 33 sites on  Navajo land  in New Mexico; and

     •    A SMOA negotiated with the Navajo Nation and Region 6,  along
          with Regions 8 and  9.

     7.63  Indian Outreach Program

     In  response  to  the  CERCLA section  126(c) requirement, EPA  submitted to
Congress a report entitled Hazardous Waste on Indian Lands on November 6, 1987.
Among other topics, the report  included an assessment of studies on the extent
of hazardous waste site  problems on Indian lands and  a recommendation for the
establishment of an education and outreach program concerning the role of Indian
tribes  in the  Superfund program.    As part  of  this  education  and  outreach
program,  the  Agency's Hazardous  Site  Evaluation  Division  (HSED) prepared an
informational booklet on  tribal participation in the  Superfund program.  This
booklet is expected to be widely  distributed among Indian tribes in 1989.

     The Agency also conducted three Indian Outreach Workshops for Indian Tribes
in June  and July  1988.    These workshops  included Headquarters  and  Regional
participation and covered  all  aspects of the Superfund program, SARA Title III
program,  the  Underground  Storage  Tank  (UST)   program,   and  Che  Resource
Conservation and Recovery Act  (RCRA)  program,  as  they relate to Indian tribes.
In addition,  the  Agency  offered to  run  special  training  courses  concerning
Superfund for Indian  tribes  at their request.  Indian tribe response  has  been
minimal.  EPA has also completed a tribal-lead remedial action  at  Tar Creek,
Oklahoma, and has a SAGA  in place with  the St. Regis Mohawk tribe in New York.


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8.0 COMMUNITY RELATIONS AND PUBLIC INFORMATION

     In March 1988, EPA issued  a  new  interim version of Community Relations in
Superfund:   A Handbook.   The  present  handbook is  a thorough revision  of an
interim version that EPA issued in  September 1986.   EPA added new material and
rewrote existing material  to incorporate new public participation requirements
of SARA  and  EPA  policies  issued since  1986.   The handbook provides  policy
requirements for coordinating community relations activities at Superfund sites,
as  well  as  supplementary techniques  that  can  be   used  to   enhance  the
effectiveness  of the  required activities.   EPA  expects to  issue the  final
version of the handbook upon promulgation of the final  NCP.   In November 1988,
the Agency issued guidance  on Community  Relations During Enforcement Activities.
As other  Superfund policy  and  guidance  documents  are  developed  and  updated,
community relations issues  and  activities will  be  incorporated.

     8.1 Community Relations

     Superfund was  created to  solve  a problem  that is national   in scope but
localized in  effect.   Through  its experience with  the  Superfund  program since
1980, EPA has  found that  its decisionmaking  is  facilitated when  the people in
a Superfund site area who  are the most  concerned about  the  site or release are
involved  in  the response  action.  Members  of  the  public  who perceive  their
communities to be endangered feel that their concerns are better addressed when
their role in the cleanup process is well defined.   EPA, therefore, established
the  Superfund   community   relations   program  as   a  framework   for   two-way
communication  between  the  members  of  the  local public  in  the  vicinity  of  a
Superfund site  and the government  agencies  responding to hazardous  substance
releases.

     The community relations program  has three  primary  objectives:

     •    To  give  the public  opportunities  to  provide  input   to
          technical decisions that  will affect  their communities;

     •    To inform the public of  planned or ongoing response actions;
          and

     •    To  serve  as  a  forum  where alternative  viewpoints can  be
          raised and conflict can be  resolved.

     8.1.1  Community Relations Requirements for Removal Actions

     Unlike past versions  of  the  NCP, which  explained  in a  single section the
community relations requirements, the proposed  revised  NCP,  in accordance with
provisions  added  by   SARA,  intersperses the  different  community  relations
requirements with the regulations  for  removal and remedial actions to which they
apply.

     8.1.1.1  The Community Relations Plan

     For all  removal actions,  the lead agency  designates a  spokesperson whose
function is to inform the community of actions taken, respond to inquiries, and
provide the public with information concerning the release.   Under the  proposed


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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


revised NCP, as  soon as  it  appears that a removal action may last  longer  than
120 days,  the  spokesperson prepares a  formal  community relations plan  (CRP).
In past versions of the NCP, the threshold was  45  days.   The purpose of the CRP
is  to  state  citizen concerns  about the  site and action,  and to  list  the
communications activities that the lead agency expects  to undertake  during the
response action.  The CRP is based on interviews  of state and local  officials,
residents, public interest groups,  or other interested parties,  as appropriate.
EPA deliberately chose not  to specify in the proposed revised NCP the  subjects
of  the  interviews or  how  the  interviews  are  conducted.    Instead,  the  lead
agency, in conjunction with the support agency, determines  the  number  and  type
of  interviews  necessary  for  the  development  of  an  accurate  picture of  the
community.

     8.1.12  The Public Comment Period

     For non-time-critical  sites and releases  (incidents which  by their  nature
allow EPA to plan the removal action for a period of at least six months),  EPA
announces  a  minimum  30 calendar day  period for  public comment on the  EE/CA,
including an opportunity  for  public meetings to  be held after they have  been
announced  in a  major  local newspaper  and the preparation of responsiveness
summaries.   The proposed revised  NCP also provides for  a  comment period  for
those emergency and time-critical sites  and releases for which  time  allows  some
planning.

     8.1.2  Community Relations Requirements for  Remedial Actions

     When the lead agency has set priorities and  evaluated  a site for  remedial
response,  community  relations  efforts  become  an  integral part of  the  site
activities that  it undertakes.   By adding  CERCLA section  117,  which  contains
public participation provisions, Congress directed EPA  to ensure  that  affected
communities would be  involved  from  the outset in developing and selecting  clean-
up actions.

     The key provisions of  section 117 include the following elements:

     •    Informing the public of the actions the  lead agency intends
          to undertake  by publishing them in the proposed plan,  a
          document   that   briefly  analyzes   the  remedial  action
          alternatives considered  in the feasibility study;

     •    Making   the   proposed   plan   available    through    the
          administrative record, which  contains  documents  that form
          the  basis  for  the  selection  of a  response  action,  and
          through publication of a summary of the  proposed  plan in  a
          major  local newspaper;

     •    Providing the public with a reasonable opportunity to submit
          written and oral comments on the proposed plan;

     •    Requiring  the  lead  agency  to  develop  a   response  to
          significant comments  received on the proposed plan and  a
          discussion  of  any  major  changes that are  made to  the
          selected remedial alternative;


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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
     •    Providing the opportunity for public meetings to be held to
          discuss  the  proposed  plan,  for  transcripts  of  formal
          meetings to be prepared, and for the transcripts to be made
          available to the public; and

     •    Explaining significant  differences.

     The  Agency applied  these section  117 provisions  to each  stage of  the
remedial process in the proposed revised NCP.  If the Agency makes a significant
change after signing the ROD,  it  publishes  an explanation of the rationale  for
doing so.  The  response selection process  includes  issuing  notices,  providing
opportunities for  public comment and meetings,  and preparing  responsiveness
summaries.  The proposed revised  NCP  includes additional avenues for community
members to play a role in the remedial design and remedial action phases of  the
site cleanup.

     8.13  Technical Assistance Grants Under CERCLA Section 117(e)

     Funds were first  made  available  for the Technical  Assistance  Grant  (TAG)
Program in fiscal  1988,  and EPA  awarded grants  to four  citizens'  groups  (see
Exhibit 8.1-1).

     8.13.1 Purpose of the Technical Assistance Grant  Program

     The  TAG  Program  is designed to  provide  funds to communities  to  seek  the
assistance of independent advisors who interpret technical information related
to cleanups at Superfund sites. The advisors provide affected communities with
a better understanding of the process of cleaning up a site,  the nature of site
conditions and  wastes,  and  the  alternative  solutions.    Ultimately,   the  TAG
program allows communities to be well-informed about Superfund and provides  EPA
and the states with informed comments from citizens living near hazardous waste
sites.

     The  Agency can provide groups of individuals with  TAGs of up  to $50,000
per site.   In accordance with the  Interim Final Rule, the Agency issues only  one
grant to an eligible site, and the community contributes  35 percent of the total
costs of the  TAG project.  EPA grants  waivers of this matching fund requirement
only in exceptional circumstances.   Applicants  may request  grants  at  any time
after a site  is  proposed for or listed on the NPL,  or proposed for inclusion on
the NPL and where a response action is underway.   Any group of individuals that
may be affected by a release or a  threatened release at any of these facilities
is eligible to receive a TAG.  Potentially responsible parties and other groups
and organizations are not eligible to receive grants.

     EPA  published  an Interim Final  Rule  (IFR) regarding the TAG  Program on
March 24, 1988.   From  the  time of publication of  the IFR to  the  end of fiscal
1988, the EPA Regional offices received 80 letters expressing  intent  to apply
for TAGs  and 13 draft or final grant  applications.   The  IFR  allowed the Agency
to begin accepting  applications from citizens groups and awarding grants without
further delay,  while  simultaneously  accepting  comments  on and  developing  the
final rule.   The TAG workgroup met in  October 1988  to begin deliberations on  the
final rule, and the Agency plans  to publish it  in  1990.


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                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                   Exhibit 8.1-1
          Communities Receiving Technical Assistance Grants
                               in  Fiscal 1988
     Region   Site Name and Location
 Grant Recipient
 Grant
Amount
       2     Love Canal
             Niagara Falls, New York
       2     Fulton Terminals
             Fulton, New York
             Lackawanna Refuse
             Old Forge Borough,
             Pennsylvania

             Industrial Excess
             Landfill, Uniontown,
             Ohio
Love Canal Environ-     $43,067
mental Action
Committee

Fulton Terminals        $50,000
Safe Drinking Water
Action Committee

Old Forge Toxic Waste   $50,000
Removal Committee
Concerned Citizens  of   $50,000
Lake Township,  Inc.
     SOURCE:   OSHER Annual Report:  Fiscal Year 1988. OSWER,  November 1988.
     8.132  Guidance on Technical Assistance Grants

     The Agency issued the  following  TAG  guidance documents:

     •    A  final  guidance,  Technical  Assistance  Grants  Program
          Activities Prior  to Issuance  of the Interim Final Rule, in
          January  1988;

     •    An interim final Citizens' Guidance Manual for the Technical
          Assistance Grant  Program in June 1988;

     •    A  final  Regional  Guidance  Manual   for   the  Technical
          Assistance Grant  Program in July 1988;  and

     •    A final  Guidance  on Technical Assistance Grants for Public
          Participation  in  October 1988.

EPA also  issued fact sheets on various  aspects  of the  program and  conducted
workshops for the  public.
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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
     82  Public Information

     EPA has developed a number  of  sources  to which members  of the  public can
turn to obtain information  about a  particular Superfund site,  about the
Superfund program in general,  or about  Superfund regulatory  developments.   In
addition, the Agency has established mechanisms  for members  of the  public to
voice complaints about Superfund actions.

     82.1  Resource Conservation  and Recovery Act/Superfund Hotline

     The RCRA/Superfund Hotline generally receives about 250,000 calls per year,
including  requests for  information  and document  requests.   The number  of
inquiries has been steadily increasing each year, and was particularly large in
the  third and fourth quarters of  FY88.   The increased  use is most  probably
because of  increased  levels of RCRA,  Superfund,  SARA,  and Underground Storage
Tank regulatory activity,  greater awareness of Hotline services, and  expanded
hours of operation.  The Hotline handled questions about SARA Title  III for the
first  time  during  FY88;   in  the  past,  the Hotline  staff  referred  callers
concerned with SARA Title III to the appropriate  state or Regional Coordinator.
The Agency  installed a telecommunications device for the  deaf (TDD) in FY89 to
make the Hotline accessible to hearing-impaired  persons.

     The  Hotline  is  EPA's  primary public  information  service for  questions
related  to  the  interpretation   of RCRA,  CERCLA,  SARA,  HSWA,  and  relevant
regulations,  as  well  as about the  environment  in general.   The Hotline  also
serves as a liaison between the  regulated community and EPA personnel.   It is
staffed  by  information  specialists,  whose backgrounds  include engineering,
biology,  chemistry,  geology,  industrial hygiene,  environmental  science,  and
environmental policy.   If  an  information  specialist cannot answer  an inquiry
directly through the Hotline's resources, a specialist refers  the issue to the
appropriate EPA  office  (e.g., the  Office of General Counsel) and  reports the
information to the caller.   The  information specialists also take requests for
publications.

     822  Superfund Docket and  Information Center

     The  Superfund  Docket  and Information  Center  (SDIC)  received  a  total  of
3,232  document  requests  during  the  fiscal year.    Of this  total,   245  were
requests  for Records  of   Decision (RODs),  805  were  requests  for  guidance
documents,  and  2,182 were  requests  for rulemaking  docket  documents.   These
figures do not reflect referrals  or  assistance of misdirected phone calls, which
are estimated to total about 7,000  calls per year in addition to those  included
in official docket operations  figures.

     The public docket is the document records center for rulemaking actions and
regulatory  decisions made under  CERCLA.  The docket also  includes  information
supporting  rulemakings  under  section  3012  of   the  Resource Conservation and
Recovery Act (RCRA).  EPA established the docket  shortly after the enactment of
CERCLA.  The function  of the docket  is to provide interested parties  with access
to regulatory support materials  for proposed and final rules.  In  addition to
serving the public right of  access by making SARA Title III documents available,
the docket  supports internal  staff  and  management information needs.
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                Progress Toward Implementing Superfund: Fiscal Year 1988


     Docket staff can distribute the following materials:

     •    Background data;
     •    Guidance documents;
     •    Public comments on regulatory actions;
     •    Federal Register notices;
     •    Transcripts of public hearings;
     •    Support documents for regulatory decisions;
     •    Correspondence;
     •    Administrative records;
     •    Operating directives;
     •    RODs;  and
     •    Signed decision documents.

     The staff  also  prepares responses  to  Freedom of  Information Act  (FOIA)
requests.   Rulemaking  records that have  had prior Office  of General Counsel
(OGC) approval  are available  to  the public for viewing at the docket office.
The  public is  allowed  access  to  docket materials  upon  announcement  of  a
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.

     823  Public Information Center

     EPA's Public Information Center (PIC) received a total of 4,515  inquiries
about the  Superfund  program during the fiscal  year,  including 4,481 requests
from adults and 34 requests from children.  About one half of these calls were
referred to  other information mechanisms, with the majority  referred to  the
Superfund Hotline.

     The Center distributes a wide variety of general, non-technical information
to the public.  EPA  publications  on all  major environmental topics,  including
Superfund, are available  through  the Center.  The Center also acts  as a referral
source.   When the public  expresses an interest in a topic  on which  there  are no
publications, the Center  informs the appropriate EPA program office, so that the
program  office  can develop  response  materials.   The PIC  maintains  about  50
different  Superfund  program  publications  on-site  and additional non-technical
publications at its Cincinnati storehouse.

     82.4  Hazardous Waste Ombudsman Program

     Since EPA established the Hazardous  Waste Ombudsman Program,  the  Ombudsman
Offices have received over 2,000 calls.  The Headquarters Ombudsman Office tends
to receive calls about  problems that are  more general  in  scope,  while  the
Regional offices tend to  receive  calls  that address specific  sites  or  problems.
All calls are held in confidence, to the extent that the  law allows. The program
has  assisted   dozens  of  environmental  groups,   worked  with   neighborhood
organizations, and trained Regional representatives to serve as local ombudsmen.
The  offices have  conducted several investigations  of  EPA's implementation of
regulations.  An  evaluation of the Ombudsman  Program is currently  underway.
                                     114

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     EPA's  Ombudsman  Offices  investigate  questions   and   complaints   about
government officials  or administrative actions and  seek to  correct  problems,
where warranted.  An ombudsman is an impartial,  independent, and informal  source
of information  for  the public.  The purpose of the Ombudsman  Offices  that have
been established at EPA  Headquarters and  each  Regional  office  is  to  assist
private citizens and members of the regulated community who have been  unable  to
resolve hazardous  waste issues through  normal  channels.   The program  is not
intended  to  circumvent existing channels  of management  authority,  nor  is  it
intended  to  establish alternative  avenues  of  appeal.   The  program  is   a
supplement to existing  institutions, not a  replacement  for them.

     The  Ombudsman  Offices lack the legal  authority  to reverse or modify any
program actions or decisions.  Based on sound information gained through contact
with the public, however,  the Ombudsman Offices may  influence  Superfund program
adjustments.
                                     115

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


9.0   EPA SUPERFUND PROGRAM ADMINISTRATION

     This chapter  documents  and describes the accomplishments achieved by  the
Agency in the administration of  the  Superfund program  during  fiscal  1988.   The
first section presents  data  on the allocation and utilization of resources  by
EPA in the implementation of the Superfund program.  The second section describes
the Superfund contracts awarded during  the  fiscal  year.   In FY88,  the Agency
diversified its  Superfund contracting procedures and delegated increased contract
management responsibility  to  the Regional offices in order to better  meet  the
needs of the  removal and remedial programs  and to  expedite the completion  of
cleanups.

     The third  section of the chapter  describes  the activities undertaken  by
EPA  concerning   Superfund  training  programs,   including  the  presentation  of
numerous worker health  and  safety  training courses and  the development  and
publication of a number  of training documents. The Agency's Superfund management
and information systems are described in section four.  The last section details
Agency activities  regarding  the  development of Superfund rulemakings, many  of
which are mandated by the new SARA provisions.   These rulemakings  include:   the
proposed revised National  Contingency Plan,  rules concerning CERCLA reporting
requirements, and  a  rule  concerning  the indemnification  of response action
contractors.

     9.1 Fiscal 1988 Superfund Resource Utilization

     9.1.1 Overview

     This section presents data and information on the  utilization of resources
from the Hazardous Substance  Trust Fund for Superfund implementation  activities
by EPA and other Executive branch departments  and agencies in FY88.   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 fiscal 1989-1991 and beyond FY91
are discussed in Chapter 14.

     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.    Regional  activities  are  funded  by  monies  transferred  to'  the
Regions.  Fiscal year and historical transfers  to  Regional  offices are  shown in
Exhibits 9.1-1 and 9.1-2.  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.
                                     117

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Progress Toward Implementing Superfund:  Fiscal Year 1988


















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Progress Toward Implementing Superfund:  Fiscal Year 1988
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                          119

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     In FY88, the Agency utilized a total of $1,497,370,300 from  the Hazardous
Substance  Superfund appropriation  for  CERCLA  implementation,  including  SARA
Title III activities.  The Agency utilized a total of $98  million  for Superfund
general interagency support to other federal departments and agencies, including
Superfund Interagency Budget transfers and site-specific interagency agreements.

     9.12  EPA Superfund Program Activities

     EPA  utilized a  total  of $1.4  billion (93  percent  of  the  total  amount
obligated  from  the  Trust  Fund)  to conduct Superfund  implementation activities
under the four major program areas:   Hazardous  Substance Response,  Enforcement,
Management and Support,  and Research and Development programs.   These activities
were supported by a  total of  2,642.2 workyears  at both EPA Headquarters  and in
the Regional offices.  Exhibits 9.1-3, 9.1-4,  and 9.1-5 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  responsible  for protecting
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.

     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.   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.   This  includes financial management to track  and report on
the use of the Hazardous Substance Superfund;  administrative  management  of


                                     120

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Progress Toward Implementing Superfund:  Fiscal Year 1988









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                                           122

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                   Progress Toward Implementing Superfund: Fiscal Year 1988
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                                            123

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


contract, personnel, information systems,  office  and laboratory services, and
safety training;  and services for  space,  utilities, and other non-personnel
support needs, which include 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:
Financial Management;  Administrative Management;  Support  Services;   Computer
Services; Legal  Services;  Office  of the Inspector General;  Office of Policy,
Planning, and Evaluation; Office  of  the Comptroller;  and 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 activities are  systematically  designed
to provide methods for sampling and analyzing hazardous waste materials  needed
for quality assurance protocols;  techniques for field response personnel  to use
in evaluating potential sites; and engineering  and other  technical guidance  to
federal,  state,  and  local officials for  immediate  response  at  uncontrolled
hazardous waste 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:
Scientific  Assessment;  Monitoring  and  Quality  Assurance;  Health   Effects;
Environmental  Engineering  and  Technology; Environmental  Processes  and  Effects;
Exploratory Research; and  Technical Information and  Liaison.

     9.13  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.   The first source  is  monies
obligated to these departments and agencies by EPA from  the Hazardous  Substance
Superfund appropriation.   The  second source  is  funds  independently budgeted  by
other federal  agencies and departments.

     EPA transfers Trust Fund  monies to other  federal departments  and  agencies
through  an  interagency  budget process  (under  Executive Order   12580)   which
utilizes two types of interagency agreements  (lAGs):   general and site-specific.
General  lAGs,   funded  through  either  transfer  allocation or  reimbursable
accounts, provide funds 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 provide funds 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.


                                      124

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
     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 14.

     For  FY88,  EPA  transferred  a  total  of  $98,023,300 from  the  Hazardous
Substance Superfund  appropriation to other  federal departments and  agencies.
Exhibit 9.1-6  presents data  on the  FY88  Superfund interagency agreements  by
department and agency.

     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 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 (NRC),  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.

     Department of Health and Human Sendees

     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 section  104,  ATSDR  is required to  perform
health assessments by  December  10,  1988,  at all sites that were listed on  the
NPL as of October  17, 1986, and on  all  newly proposed sites  within one year of
the  date of  proposal.   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.
                                      125

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   Exhibit 9.1-6
         Fiscal 1988 Superfund Inter agency Support  Resources
Dollars
(in thousands)
Federal Department or Agency
Department of the Interior
Department of Transportation
Department of Health and Human Services
Department of Commerce
Department of Justice
Department of Labor
Federal Emergency Management Agency
TOTAL
SOURCES: EPA Superfund Budget Documents.
Actual
$ 1,113.5
3,027.6
42,999.9
2,429.4
16,373.0
380.9
2.784.0
$69,108.3

Planned
$ 1,253.5
4 , 948 . 2
43,000.0
2,280.1
16,373.0
L,008.2
6.092.6
$74,955.6

     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.

     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.
                                      126

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     Department of Labor

     The Occupational Health and Safety 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,  as  well as 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 Superfund Contracting

     9.2.1  Overview

     EPA manages contracts in five major categories to  implement  the Superfund
program:

     •    Headquarters/Regional  policy implementation  analysis  and
          support:   Eight  contracts,  with  a  potential  value   of
          $86 , 276 ,167 ,  supported Headquarters and Regional management,
          analytical,  and  technical development  and  implementation
          programs.  Under  these contracts,  contractors provided both
          technical and non-technical assistance.

     •    Contract  laboratory  services:    One hundred  seventy-two
          contract  laboratory services contracts,  with a potential
          value of  $211,875,557, were  active in FY88  (these  figures
          do   not   include  subcontracts   for   special   analytical
          services).  The Contract Laboratory Program  (CLP)  provides
          laboratory support  for both  removal and  remedial  actions.
          The  greatest  number of Superfund contracts fall into this
          category.

     •    Removal  action  support:     Fourteen  contracts,   with   a
          potential  value  of $899,767,335,  supported  the   removal
          program.  Removal program contracts provide EPA with support
                                     127

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


          services in emergency response, other removal actions, spill
          prevention, and analytical services.

     •    Remedial  action  support:    Thirty-seven  remedial  action
          contracts provided  EPA  technical  assistance during RI/FS,
          remedial design, and construction stages of response.  These
          contracts have a potential value of $3,640,675,544.

     •    Enforcement support:   Five enforcement contracts assisted
          EPA  in cost  recovery  and litigation  support operations.
          Combined they have a potential value of $135,444,683.

     Exhibit 9.2-1 lists FY88 contract awards and their potential value.

     9.2.2  Contract Laboratory Program

     Prior to  the  Superfund program, there were  few firms with experience in
addressing hazardous  waste site problems.   The capacity  to  conduct the work
involved in a program of this size was simply unavailable in the private sector.
Because the Superfund program had to rely  on  contractors, the program could not
progress until qualified firms expanded their staffs, developed operating and
management procedures  for  contracts of  such magnitude  and  complexity,  and
acquired  the appropriate  scientific and  engineering expertise.   Laboratory
capacity was a critical problem.   Samples  from the rapidly  expanding Superfund
investigations  caused  an  almost  exponential  growth  in   required analyses,
resulting in a national laboratory capacity shortage.   The  shortage  exacerbated
the delays in investigations for remedial actions.

     EPA's Contract  Laboratory Program has worked  with increasing success to
build up  the nation's  laboratory  capacity.    The  program has  also worked to
ensure  that  the  quality  control  and chain-of-custody  procedures  required to
yield analyses that will hold up in court are in place.  The CLP was  established
in  1980  to   provide  large  volume,  low-cost  analyses,   and  today  provides
laboratory services for removal,  pre- remedial,  and remedial actions.  Depending
on  capacity  needs,  the  Agency  awards  multi-year  contracts  for  organic,
inorganic, and dioxin analytical services.

     In fiscal 1988, 121 laboratories had CLP contracts in place.   Fifty-eight
contracts were awarded during the  fiscal year.  At the end of FY88, CLP capacity
was measured at  236,550 samples:   the  total  number of samples that the Agency
could schedule active laboratories to analyze during  a calendar month.  All of
these figures represent not only  increases over the  CLP's FY87 performance, but
also  the  highest  levels of  performance  recorded  to date for  the Superfund
program.

     During  the  fiscal  year,  the CLP  was  able  to meet  Regional  demand for
analytical services.   The CLP performed  a total  of 77,729 routine analytical
services  (RASs)  and  43,315  special analytical  services   (SASs).    RASs  are
contracts which  specify the  procedures  a particular  laboratory will follow,
while SASs are contracts which include unique sampling work (e.g. ,  a  quick turn-
around analysis).  Both  of these figures represent  annual highs for analytical
services performed by the CLP.  Total expenditures by the CLP for these services
in FY88 were $33,702,502 for RASs and $12,029,164 for  SASs.  Exhibit 9.2-2

                                     128

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   Exhibit 9.2-1
                        Fiscal 1988  Contract Awards
                                                      Total
                                  Number of          Potential
             Contract                Contracts          Value ($)
          General  Policy and         5               32,869,366
            Technical  Support

          Response Support:

                Laboratory           58               58,559,472

                Removal               7              152,118,150

                Remedial (ARCs)       18            2,672,608,008

          Enforcement  Support        3                2,444,683


          NOTE:  Figures represent the total potential value over the life of the contract.

          SOURCE:  Active Superfund Contracts Listing, FY 1988-1989, EPA Office of
                 Administration.
provides  a  breakdown  of these  numbers  by  the  type  of  analytical  service
performed.

     Presently,  the average time  for delivery of  analytical results  is 35-40
days, a duration well within  EPA's  stated target.  Continuing efforts to increase
CLP automation may  reduce the delivery time  in the  near  future.   EPA determined
that a reduction in the  time  necessary to screen CLP data for contract compliance
and to process  analyses would save resources.   In the past,  all  CLP data were
either reviewed manually  or were manually entered into a computer for screening.
An automated approach was designed to address this  problem.   By March 31, 1988,
contracts  were  in  place  to  provide  for automated data transmission,  thereby
significantly  reducing human  transcription  errors and  reducing  overall data
review costs.

     Overall, the management of analytical services has improved and streamlined
the cleanup process.  The CLP maintains  three data  bases  on  Superfund analyses.
Each data base  serves a unique  purpose, allowing the  CLP to  monitor analytical
activities  over the  course  of the  Superfund program.   In  addition,  the  CLP
integrates these data bases  into four data support  systems  that ensure that the
program controls the  quality of work performed.  Exhibit 9.2-3  describes these
CLP data bases  and  data support systems.
                                      129

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                   Exhibit 92-2
                       Contract Laboratory Program
              Superfund Analytical Services for Fiscal 1988
                                  Number of Samples
                                  (Percentage of Total)
                        Expenditures
                     (Percentage of Total)
    ROUTINE ANALYTICAL SERVICES:

        Organic
        Inorganic
        Dioxin
        TOTAL
    SPECIAL ANALYTICAL SERVICES:

        Organic
        Inorganic
        Dioxin
        Other
        TOTAL
34,191  (44%)
37,563  (48%)
 5.975   (8%)
77,729 (100%)
16,024  (37%)
23,582  (54%)
 1,982    (5%)
 1.727    (4%)
43,315 (100%)
$27,478,849   (82%)
  5,289,411   (16%)
    934.242    (3%)
$33,702,502  (101%)
$ 5,766,974   (48%)
  3,785,331   (31%)
  1,870,387   (16%)
    606.472    (5%)
$12,029,164  (100%)
    NOTE:       Percentages may not total 100% because of rounding.  Totals do not include samples
               taken for RCRA activities, which the CLP also supports.

    SOURCE:      EPA Contract Laboratory Program, Sample Management Office.
     As more  Superfund sites move  from the SI  stage  to the RI/FS,  RD,  and RA
stages, the CLP's capabilities must  change.   In particular, the  CLP must have
the  capability  to  analyze  samples   with  lower  concentration  levels  of
contaminants.   The Agency held several meetings during  the fiscal  year with
Regional and CLP staff to develop contracts for analyzing lower detection limits
and to ensure  that contamination introduced by the laboratories  themselves is
minimized.

     Environmental Services Assistance Team Contracts

     Due  to significant   increases  over the  past  few  years  in  the  need for
Regional support on environmental services, EPA awarded two contracts  in support
of the laboratory program  at the end of FY87.   These two Environmental Services
Assistance  Team   (ESAT)  contracts  are  worth  $35  million each and provide
assistance  to  EPA's  Regional  offices  in  laboratory,  analytical,  and review
services.  The two ESAT contracts cover  different geographical zones (the eastern
zone  includes  Regions 1-4 and  the western zone  includes  Regions  5-10 and
Headquarters)  and both are essentially  fully  operational  at this  time.
                                      130

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            Progress Toward Implementing Superfund:  Fiscal Year 1988
                              Exhibit 9.2-3
                   Contract Laboratory Program
       Analytical  Data Bases  and Data Support Systems
     Name
Date Initiated
       Purpose
DATA BASES:

Superfund Statistical
Results Data Base
   1980
To estimate the occurrence
and concentration of
compounds at NPL and non-NPL
sites.
Contract Compliance Screen   1985
Data Base
Superfund Analytical
Results and Quality
Assurance Data Base
   1987
To evaluate laboratory
methods and performance.

To provide analytical
results and quality
assurance information to
data users.
DATA SUPPORT SYSTEMS:
Automated Data Review        1982
(ADROIT)
Statistical Results Data     1984
Base (STAT)

Contract Compliance          1985
Screening  (CCS)

CLP Analytical Results       1987
Data Base  (CARD)
                 To provide quality
                 assurance data for selected
                 samples.

                 To provide analytical
                 results of samples.

                 To provide quality control
                 compliance data.

                 To provide summaries of
                 analytical results and
                 quality control compliance.
SOURCE:  EPA Contract Laboratory Program,  Sample Management Office.
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     The initial  staffing  of the two ESAT contracts  provides 92 workyears  to
the Regions  and  10  workyears to zone  management offices  and  a Headquarters
technical team, with a  provision for significant increases in support  through
the exercise  of options.   The most notable contribution  of the ESAT teams  to
date has been in data review.  Regions 4 and 5  are now current on reviewing CLP
data packages after years of significant backlogs.  Also,  indemnification clauses
were  recently  placed  in  the ESAT  contracts  by formal  modification.   The
modifications  will  permit  ESAT  personnel to  go on-site  to  perform  quality
assurance oversight  of  sampling  and  field analysis  activities.   Several  teams
in the western zone are presently staffed over ceiling, using hours not utilized
during mobilization,  in support  of Regional requests for additional work and
resources.

     During  the  fiscal  year, the Agency formed workgroups  to  address data
useability and continues  to  develop quick-reference charts  for articulating
quality  control  responsibilities.    The Agency's  Hazardous  Site   Evaluation
Division  conducted   on-site  audits,   data audits,  and  quarterly  performance
evaluations at  all CLP facilities.  All contracts managed by  HSED's  Analytical
Operations Branch (AOB) were  transferred to EPA's Contract  Management Division
in Research Triangle Park,  North Carolina.  The AOB continues to identify the
Regions' anticipated needs for new types of analytical services and to  track
the quality of  analytical methods employed.

     923  Response Support Contracts

     Removal Support Contracts

     The removal program has traditionally been supported  by Emergency Response
Cleanup Services (ERGS)  contracts.  Under the ERCS contracts, contractors perform
removal  actions on  a  zone basis:   Zone I consists  of Regions  1-3; Zone  II
consists of Region 4;  Zone III consists of Region  5;  and Zone IV consists  of
Regions 6-10.   EPA has announced  its  intent to break  up zone  IV  into two
separate ERCS contracts, and has  issued a Request for  Proposal (RFPs) for  these
contracts.

     The ERCS  contracts  for Zones I, II, and  IV were awarded in FY87  for one
base year and three option years.  In June 1988,  the Agency exercised the  first
option year for the Zone I and II contracts.   The first  option year of the Zone
IV contract  was exercised in  February  1988.   The Zone III ERCS contract was
awarded in October 1987 for one base  year and  three  option years, arid the  first
option year was exercised  in  September  1988.

     In  addition, EPA  developed and began  implementation of  a strategy for
awarding smaller  removal contracts on a Regional  basis, i.e., "mini-ERCS."   In
FY88,  mini-ERCS contracts were  awarded in Regions 2,  3,  and  4.    The  awards
included small  business contracts in  Regions 2  and 3.   In FY87,  four mini-ERCS
contracts for dioxin excavation and storage work in Region 7 were signed for one
base year  and four  option years  each.   The Agency  exercised the first  option
year of each  of these contracts  in FY88.

     The removal  program is also supported by Technical Assistance  Team  (TAT)
contracts, which serve as adjuncts to  the ERCS contracts and provide  for initial
site response  support,  determinations of the  size and  nature of the site, and

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support for On-Scene Coordinators during  actual  cleanup.   The  TAT contracts are
performed on a zone basis.  The eastern zone covers Regions l-5>, the Emergency
Response Team,  and Headquarters, and the western  zone covers Regions 6-10.  These
contracts have  a  combined potential value  of $219 million over a five-year period
of performance.   Both  the  eastern and western zone TAT contracts were awarded
in FY87  with a  two-year  base year each plus a two-year  option.   The Agency
exercised  the  two-year option for both  of these  contracts  in  August  1988,
extending the period of performance from  October 1,  1988,  through September 30,
1990.

     One of the Region  3 mini-ERGS contracts that was awarded in FY88 was awarded
to a minority  firm  under  the  provisions  of  Section 8(a)  of the Small Business
Act.   In addition, EPA exercised the second option  year of a Region 5 mini-ERCS
contract that was awarded to a minority firm in FY87.  In May  1988, the Agency
terminated a mini-ERCS contract in Region 4 that was  awarded to a minority firm
in FY87.

     Remedial Support Contracts

     In FY88, EPA began the implementation of the Alternative Remedial Contract
Strategy (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,  injecting  more
contractors  into  the   remedial  contracting  program, and promoting  project
continuity.  Under ARCS, numerous smaller remedial response contracts are awarded
continuously in each Region or, in some cases, in several Regions combined.  Work
is 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  Regions  will have  complete responsibility  for management of the
ARCS contracts.

     EPA awarded  the first ARCS  contracts in Regions 3  and 5  in January 1988.
As of October  1988,  EPA had awarded 18 of the  anticipated 45 ARCS contracts.
The remainder were awarded by  July 1989.  The ARCS contracts will range from $60
million to $250 million in potential value for 10-year periods of performance.
ARCS contracts contain large  subcontracting pools  to maximize the numbers of
contractors participating, as do the current remedial contracts.

     Prior to  the use  of  the  ARCS contracts,  EPA used Remedial Planning (REM)
contracts to support the activities of  the remedial program. There are presently
three large REM  contracts  (II, III, and  IV) and two smaller minority firm REM
contracts that are active.  Because these existing REM contracts cannot supply
the necessary  technical level of effort hours  to  support identified Regional
project needs,  EPA is developing  alternative means  of supplementing REM support
to avoid program schedule  delays.  Alternatives  being developed include the use
of the  U.S. Army Corps of Engineers (COE) ,  the  U.S.  Bureau of Reclamation
(BUREC), and ARCS contracts when available.

     The Agency formed a workgroup during FY88 to develop a contracts training
program for remedial project managers.  The program would  provide the tools and
information  necessary  to  ensure  that  tasks  are managed  more efficiently and
effectively.   EPA felt that it was imperative  that  RPMs  be  provided adequate
training  in contract  management  to  improve the  overall  management of  the

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Superfund program.   The workgroup completed course  development  by the end  of
FY88.   The  RPM  contracts  training course will  be a  three-day  course with  a
potential audience of all RPMs, project officers,  and  contract officers.

     92.4  Contract Operations Review and Assessment Staff

     Because of the Superfund program's extensive reliance on contractor support,
the planning, management, and administration of Superfund contracts has become
one  of  the  Agency's  most  important  operational  tasks.   Superfund  personnel
involved  in these activities  are very visible  and are  subject to  extensive
oversight from a variety of external sources.   In order to provide  for internal
proactive management  of the  Superfund contract program,  EPA established the
Contract Operations Review and Assessment Staff (CORAS),  within the  Office  of
Program Management (0PM) in FY88.

     CORAS  reports to  the Director of the Office of Program Management (0PM),
within OERR.   The mission of CORAS  is to assist OERR in the  integrated and
proactive management  of the  Superfund program's  hazardous waste site cleanup
activities,  focusing on efforts undertaken through the use of contracts and  other
external relationships, such as interagency agreements,  cooperative agreements,
and grants.    CORAS will assist Headquarters  and Regional contract managers  to
effectively carry out their responsibilities.  The staff will  act  as consultants
to contract managers  to facilitate the resolution of problems and to identify
needed training programs and management tools.

     CORAS  also  periodically  distributes  a bulletin that provides a  forum for.
information exchange regarding Superfund contract management  issues.   The  first
CORAS bulletin was distributed  in  September 1988.

     93 Training Activities

     During FY88, OSWER conducted  approximately 80 different  training courses,
seminars, and workshops.  In all,  over 300 sessions were attended by  more than
10,000 individuals.   EPA placed a particular emphasis on training programs  to
inform state and Regional personnel of the  requirements for compliance with  other
statutes:   courses were delivered in five of the Regions during FY88  and were
scheduled to be offered in the  remaining five Regions in early FY89.   To address
the increased demand for all Superfund training and  the need  to  explore future
alternative training methods,  OSWER completed the development in FY88 of a  five-
year training strategy.  The purposes of this strategy are to provide perspective
on the past and present direction of OSWER's training program,   identify  clear
goals and objectives for the program,  and  propose  changes or  enhancements that
will make the program more responsive to  current and anticipated needs.

     Also during  FY88,  the Office of Program Management and Technology (OPMT)
completed an assessment of training and technology transfer needs that was used
extensively in the planning of OSWER training activities,  and a training course
catalog and corresponding  calendar that  presented current information on all
training courses offered during the fiscal year.  OSWER also began  implementation
of the  Superfund Work  Force  Planning Project, a  comprehensive  effort by the
various OSWER  divisions to  improve the training,  retention,  and management  of
Superfund personnel.
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     93.1  Overview

     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;

     •    Identification  of  training requirements;

     •    Training  development, delivery, and coordination within and
          among Program Offices and  the  Regions;  and

     •    Management  and training   support   to  EPA  Headquarters,
          Regions,  and states,  as  requested.

The  overall  approach of  the OSWER training  program  focuses  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  Office  of Program  Management  and Technology (OPMT)  within OSWER  is
responsible  for planning  and policy  development  in  the  areas of research  and
development,  technology  transfer,  and  training.    This office  has  specific
responsibility for  the development and implementation of  long-term training and
technology transfer strategies for  OSWER,  in conjunction with  the Office  of
Research  and Development  (ORD).   Technological  innovations developed  through
research and demonstration programs,  such as the Superfund Innovative Technology
Exchange  (SITE) program,  are incorporated into technology transfer activities
and training to ensure that advances in knowledge  and skills are  made  available
to Superfund staff.

     Future of Training Programs: OSWER's Five-Year Strategy

     The  Agency completed the  OSWER  1989-1993 Training  Strategy during  FY88.
The strategy sets a clear direction  for  training efforts, addresses management
issues, and promotes greater coordination at  all levels.  It affects  all  OSWER
Program   Offices,  Headquarters   staff,   and  Regional   waste  management,
environmental services,  and emergency and remedial response divisions.   The aim
of this new training strategy is to take a broad perspective of past and present
OSWER training activities, to  identify clear  goals and objectives for  training
activities, and to create  changes  that will  make the program more responsive to
current and anticipated needs.   The strategy will also help to promote necessary
communication  and  cooperation  among  the various Program Offices,  as  OSWER
programs evolve towards  addressing common problems and as training needs become
more similar.

     The  strategy reflects  recent developments in the Superfund program  that
have led  to  changes in the  direction of OSWER programs.   These developments
include  a shift  in  emphasis  from  the development  of  regulations  to  the
implementation of programs,  expedited enforcement activities, congressionally
mandated  acceleration  of  remedial  activities,  and increased emphasis   on
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assisting the  states  in managing  and implementing  solid  and hazardous waste
programs.

     The OSWER  five-year  strategy sets out  several  broadly defined goals  for
OSWER training activities in the long-term,  including:

     •    Improved  quality   control,  through   continued   central
          management   of   the   training   program    and    improved
          implementation of  training policies, as set out  in OSWER
          Training Policies and Procedures (issued as OSWER Directive
          No. 9018.00-2, September 30, 1987).

     •    Strengthened coordination and communication  through active
          participation of all  Program Offices and Regions  in OSWER
          training activities.

     •    Development of structured curricula based on job performance
          needs  of  the  hazardous   and  solid  waste   programs   to
          concentrate resources in fulfilling  priority needs.

     •    Enhancement  of  Regional  and  state  training  capability
          through increased resources  and improved management systems.

     •    Emphasis on  the use of alternative training  delivery methods
          to provide wider dissemination of  training materials.

     •    Institution of  training monitoring and evaluation systems
          to  provide  greater   control  over  the   efficiency   and
          effectiveness  of all  OSWER training.   The  systems will
          maintain  up-to-date   information   on  current   training
          activities,   document"  program successes,  and  ensure   the
          quality of OSWER training.

     932  Meeting Critical OSWER Training Needs in Fiscal 1988

     The  OSWER Training  Staff,  in   their  function   of  coordinating  training
activities, works with the Program Offices and Regions  in  conducting  a  number
of  projects related  to  implementing the  training   policies and  procedures,
assisting  in the implementation  of   Superfund training,  and coordinating  the
development of training that  cuts  across program areas.  Major factors that have
affected the implementation of  Superfund  training  during FY88 include:

     •    The need to move toward  alternative  delivery mechanisms in
          order  to meet  increasing training  needs;

     •    The impact of the Superfund Amendments  and Reauthorization
          Act (SARA) on program operations and training  authorities,
          including training efforts  of  other federal  agencies  and
          private industry;

     •    The   implementation  of  OSWER   training  policies   and
          procedures;
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     •    Plans  for  implementation  of  the  Superfund Work Force
          Planning Initiative; and

     •    New  management  initiatives,  such as the  OSC/RPM  Support
          Program.

     OSWER Annual Training Plan for Fiscal 1988

     The objective  of the  OSWER Annual Training  Plan is  to comply with EPA
training policy, as spelled out in the EPA Training and Development Manual, and
to  provide  a  basis  for  comprehensive planning  and  coordination  of OSWER
training.   The  goal  of  the  annual plan  is to  facilitate communication and
coordination among OSWER organizations, to reduce  duplication of  effort,  and  to
ensure the quality and consistency of training across OSWER  offices.  Each  of
the  Program Offices   and  Regions  were requested to  submit information  to
Headquarters  regarding their  anticipated  training  development  and delivery
initiatives during the fiscal year; this information  was then incorporated  into
the annual plan.  Also addressed in the annual plan are ongoing OSWER efforts
at management and coordination of  training  across  Program  Offices.

     EPA training policy requires the completion of Training Planning Documents
(TPDs) for all  planned training development.  The information contained in these
TPDs defines the problem to be  addressed  by training, describes the intended
target  audience, outlines  the  overall objectives  of the  specific training
program, and provides  more  detailed information regarding  the subject matter,
scheduling,  resources, personne.1,  and  estimated  costs of  the training.  The
information  contained in TPDs was  used during FY88  by training coordinators
throughout OSWER in making  decisions regarding  requested funding support.

     OSWER Training and Technology Transfer Needs Assessment

     OPMT conducted the needs  assessment  for FY88 to support OSWER1s resource
estimates for FY88 and FY89, to help establish training priorities and determine
where existing courses are most needed,  and  to ensure that current plans reflect
the ongoing needs of  hazardous and solid waste staff in the  field.   To  assist
in  the  assessment,  OSWER Division Directors provided input about  additional
program  priorities,  relevant  changes  in  program directions and operational
procedures with  impact on  training needs,  and areas requiring training  course
development.

     The  needs  assessment  was  used  extensively   by  the  Regions  and Program
Offices  in planning and  scheduling courses.  It pointed to  the need  for OSWER
to work with the Program  Offices  in developing and managing training  needs  that
cut across program  areas.   Training  in this category includes orientation  or
overview types of training, ground-water training, health  and safety  training,
and technology transfer seminars;  these areas will be  discussed below.

     OSWER Training Course Catalogue and Training Calendar

     In addition to the needs assessment, OPMT  also compiled a Training  Course
Catalog  and  a  corresponding Training Calendar  for FY88.   The course catalog,
printed  on a  semi-annual   basis,  and  the  training  calendar, with  quarterly
updates,  provide Superfund personnel  with information on currently offered


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courses, including:  a brief course description, the contact person, the dates
and the  locations  of the  course,  and the length  of training.   For the FY89
edition  of  the  course  catalog,  additional  information  will  be  provided,
including the  course  goal,  target audience,  alternate  courses to choose from
when a  desired course is full, as well  as a complete  index  of  all available
courses.

     933  Priority Training Program Goals and Related Training Courses

     Current OERR training activities  focus on furthering two of the major broad
objectives  of  the Superfund  program:    (1)  to  stabilize  actual  or potential
threats  from  releases  of  hazardous substances,   and  (2)   to   ensure  that
environmental threats posed by uncontrolled hazardous waste sites  are addressed
quickly.  Training courses were offered in EPA Headquarters, in the EPA Regions,
and at  Emergency  Response  Branch Training  Centers  in  Cincinnati,  Ohio,  and
Edison,  New Jersey.    The  main priority  areas  addressed  by  training  courses
during  FY88 include:  management,  emergency  response,  compliance  with other
statutes  and regulations,  program guidance,  health  and safety,   ground-water
technology,  risk  assessment  and  evaluation,  emergency  preparedness,   and
technology  transfer.   These areas and the related training  courses designed to
specifically address them are discussed in greater detail below.

     Management Improvements in Technical and Programmatic Capabilities

     OERR training efforts  to enhance its work force capabilities are geared
toward  professional  development  and  the  improvement   of   overall   program
effectiveness.   Courses  related  to  this  goal  are  designed  to  increase  the
programmatic and technical capabilities  of  Headquarters,  Regional,  and  state
personnel.   Courses offered  in this area for the first time during the fiscal
year  include:    a CERCLA orientation  course  for  both  new  and experienced
personnel,  a  course  on  the  management  of  construction  activities  in  the
Superfund program designed for Regional and state project managers, and a course
providing  an  overview  of  the  full  range  of  hazardous materials   cleanup
technologies.

     Environmental Response Team Training

     The Emergency Response Division's Environmental Response Branch,  also known
as  the  Environmental  Response  Team  (ERT),  has  been presenting a  series  of
Hazardous  Materials   Incident Response  Training courses  since  1979.   These
courses are  open to  federal,  state  and local officials, and to personnel from
private industry.  Although the number of courses offered  has  increased to  190
weeks of courses in FY88, the need for additional courses  continues  to  outpace
the number  available.   Course titles  offered in FY88 include  Air Surveillance
for Hazardous Materials,  Incident Mitigation and Treatment Methods, and Sampling
for Hazardous Materials.

     To  meet  the  demand for  hazardous  materials  training  courses,  ERT  has
started a program that  allows  other  training  organizations  to  present  these
courses.  The  organization must agree to  follow criteria established by ERD to
maintain  the quality  of  the courses before being accepted  to  present them;  ERT
will  then provide all  of the materials needed  to  present the  courses.    No
funding will be provided to an organization accepted into the  program,  although


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ERT will assist in presenting the  first  few  courses.   Through  this  cooperative
program, the number of EPA courses presented will  increase without a concurrent
increase in the training budget,

     Training on Revised Program Guidance

     With the recent proposed revisions to the National Contingency Plan (NCP),
OSWER has begun to develop new training and revise existing training to  reflect
these  revisions.    Also  planned  are  guidance documents  to  accompany  these
training programs.   A two-day workshop  to provide an overview of  the  revised
RI/FS  guidance was  developed and  delivered  in all  ten Regions.    Still  under
development are courses  related to  revisions  in the Hazard Ranking System (HRS),
Preliminary  Assessment/Site  Inspection  (PA/SI),  and Implementation  of  the
Regulations   on   Reportable  Quantity   (RQ)  Adjustments  and   Notification
Requirements.   Training  courses related  to revisions  in guidance  regarding
Records of Decision (RODs)  and Remedial Design/Remedial Action (RD/RA) also have
been proposed.

     Compliance with Other Statutes and Regulations

     EPA has  placed  particular emphasis  on  training programs  to  inform  state
and Regional  personnel  of  the  requirements  for  CERCLA compliance with  other
statutes.    Section   121(d)  of  CERCLA  requires   that,   in the  planning  and
conducting  of remedial  actions at  Superfund sites,  cleanup  activities must
comply with applicable or relevant  and appropriate federal or state requirements
(ARARs).  Compliance  is  required at the completion of  the  remedial  action  for
hazardous substances, pollutants,  or contaminants  that remain  on-site.

     EPA's  Office of Emergency  and  Remedial Response   (OERR)  is  providing
training courses  to  EPA Regional and state personnel  on  information regarding
ARARs.     The  goal  of  the  training  program is  to  improve   performance   in
implementing the requirements relating to ARARs by providing EPA Regional  staff
(Regional Project Managers, On-Scene Coordinators, Regional Counsel and  program
staff), state staff,  and contractors with guidance on identifying  and complying
with ARARs.  In addition, a guidance manual to accompany these  training  courses
has been developed.

     A  pilot training  course  and  evaluation  workshop was  presented to both
Regional and Headquarters staff in Washington, D.C.,  in May 1988.   The training
course was then delivered in Regions 2,  3, 4, 5, and 9 in June,  July, and August
of 1988.  Due to  requests from the remaining  Regions,  the course was offered in
Regions  1,  6, 7,  8, and  10  in November  1988   through  February  1989.    Two
additional sessions will be offered to Federal Facility personnel.

     Health and Safety

     Health  and  safety   is  an   area   of   substantially  increased training
responsibility because   SARA  amended  CERCLA  to  require  40 hours  of  safety
training  for  any public  or  private  workers  involved  in  hazardous  waste
management or  cleanup,  and 8  hours of additional supervisory  safety  training.
Superfund1s ERT Training Program includes three courses that exemplify the type
of safety training mandated under SARA.  The National Institute  of  Environmental
Health  Sciences,  under  an  interagency agreement  with OSWER,  is  administering


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health and safety  training  grants  which total 10 million dollars per year for
a five-year period.   To satisfy the large reported need for health and safety
training  demonstrated  in  the  FY88 Needs  Assessment ERT  offered additional
courses  in  this  area  and  through Regional  efforts  conducted  through their
technical support contractors.

     Ground-Water Training Initiatives

     During the  fiscal  year,  basic ground-water training was provided through
Regional  training initiatives  and  through the  ERT Training  Program course
Introduction to Ground-water Investigation.  The Agency also began a number of
separate  initiatives  in FY88.   OSWER continued in  the  process of installing
ground-water work stations in the Regional offices  and providing  instruction in
their use, and sponsored a project  to  provide computer-assisted job training
aids for quality assurance in evaluating  ground-water monitoring plans.  OPMT,
in coordination  with  the program offices,  began  development  of a new ground-
water curriculum to provide for  the development of a new required ground-water
training  program.    Also,  the  Office  of Research  and  Development  (ORD)  is
planning  a  series of technology  transfer seminars  in  ground-water computer
modeling  to  be  provided by the  R.S.  Kerr Environmental  Research Laboratory
staff.

     Risk Assessment

     Critical  training  needs in risk assessment  are being met through both
Agency-wide and  Superfund  initiatives.    Agency-wide  training  in this area is
being coordinated by  the Office  of  Policy and  Program  Evaluation (OPPE).  OERR
training  in  risk  assessment   includes   two  courses:    Environmental  Risk
Assessment,   offered   through  the ERT Training Program,  and  Superfund Public
Health Evaluation Process,  presented during late FY88 as  a  framework for public
health assessments at Superfund  sites.

     Emergency Preparedness

     During the fiscal year, work was performed on a proposal to package certain
of  the   ERT   safety   and   preparedness  courses  for  dissemination  through
universities  and state  organizations who  can meet  established criteria for
quality  control.   The  OPMT Preparedness  staff also  worked on coordinating a
joint  training  course  with  the  Federal  Emergency  Management  Agency  on
contingency  planning  and   is  currently  evaluating  other possible  training
development  initiatives.  Courses  offered in this area  during FY88 include
Hazardous  Materials  Response   for  First  Responders,   Hazardous  Materials
Contingency Planning, and SARA Title III  Information Management Workshop.

     The Preparedness Staff addresses training needs  in emergency preparedness
through Regional  training efforts,  and  through the coordinated efforts of the
National Response Team  (NRT) Training Subcommittee.  NRT Training Subcommittee
efforts include:

     •    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;
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                 Progress Toward Implementing Superfund: Fiscal Year 1988


     •    The establishment of federal,  state and local organizational
          relationships; and

     •    Gaining private industry support for a coordinated training
          system.

Regional  efforts include  the  development and  delivery of  a number  of First
Responder training courses  targeted  to  state  and local officials.

     Technology Transfer

     The  Center  for  Environmental   Research  Information   (CERI),  under  the
direction of  the OSWER/ORD Research Committee, offered  a series of technology
transfer seminars during the fiscal  year.  These seminars,  delivered primarily
to the Regional  offices, are directly relevant  to Superfund training needs and
program  objectives.   They  are directed  toward disseminating  information and
result from the development and evaluation of innovative technologies and waste
management strategies.  Among the technology transfer seminars delivered during
FY88 are the following:  Transport and Transformation of Subsurface Pollutants,
Alternative Treatment Technologies  for Superfund  Waste Sites, Solvent Waste
Reduction Alternatives, Corrective Actions Series, and Hazardous Waste Landfill
Design.

     93.4  Organizational Improvements in Fiscal  1988

     During  the  fiscal year,  the  OSWER training program made  significant
progress as the result of several organizational improvements related to greater
coordination of  efforts and an increased management commitment  to  training and
technology transfer.  These organizational improvements  are discussed below.

     Alternative Training Delivery Methods

     The target  audience for OERR training has  expanded  significantly with the
addition of new authorities for training  of  state, local,   and  private  sector
personnel.    In addition,  an increase  in  Superfund  staff and  new  program
directions have  led  to  the need  to implement new training methods to increase
the efficiency  of training resources.   For  these reasons,   OERR developed the
Training Delivery Feasibility Study to review the various delivery alternatives
that will meet current and  future OERR needs.  The Study recommended appropriate
solutions and laid out  implementation plans and costs.

     Superfund Work Force Planning Project

     The Office  of Program Management and Technology (OPMT) and the  Office of
Emergency and Remedial Response (OERR),  in coordination with the Office of Human
Resources Management (OHRM) and the Office of Waste Programs Enforcement (OWPE)
combined forces  to implement  recommendations  made in the Superfund Work Force
Planning  Study  and  the  subsequent  GAO Report  to  Congress  on  Superfund
Improvements Needed  in  Work Force Management.   The result of these efforts to
improve the  training,  retention, and management of  the Superfund work force
included  the  creation  of  a new,   revised  training  program  for  On-Scene
Coordinators  (OSCs)  and Remedial  Project Managers (RPMs).   The  purpose  of the
OSC/RPM  Support Program  is to  provide  OSCs,  RPMs,  and  others   involved  in


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hazardous materials cleanups with specific  career  development  arid enhancement
opportunities.

     The OSC/RPM Support  Program includes:   the development of courses and case
study institutes with  emphasis  on contracts management,  legal  training, site
management, and complex  technical problems;   support for continuing education
with  multi-year employment  commitments;   design  of  an OSC/RPM  structured
training program;  awards and recognition for outstanding performance;  support
for  professional  development;    a review  of  compensation and  classification
practices; and improvement of the Superfund workforce planning techniques.

     In its effort to  use  this  program to  provide  better career opportunities
for personnel and to retain them longer, OPMT and OERR have worked with advisors
from various branches  to assure that  the  program will meet  employees'  needs
within program and personnel requirements.  Notable  progress  has  been made in
several areas,  including:

     •    Superfund/University Training  Institutes:  Five institutes
          have been funded for FY89 -  East Tennessee State University,
          University of  Cincinnati,  University  of  Nevada-Las  Vegas,
          University of  Georgia,  and a  consortium of University of
          Oklahoma, Oklahoma State University, and Rice University.

     •    Superfund Training Academy:  Work is  underway to finalize
          a curriculum of required  courses for  new  employees  to be
          provided in  two four-week  sessions in one  location.   The
          first four-week  session  is expected to be  held in Spring
          1989.

     •    Structured Training and  Evaluation Program (STEP):   OPMT
          and  OERR are  presently developing criteria recogni2:ing
          employee accomplishment of specific requirements for various
          developmental  levels.   Certificates of accomplishment will
          be provided to several select senior employees, who will be
          grandfathered  into the program.

     Expanded Superfund Curriculum

     During FY88, OSWER  reviewed and expanded its  training curriculum to meet
critical   Superfund    training  needs.      These  revisions   were   based  on
recommendations and data contained in the  FY88  Training Needs Assessment,  the
Superfund  Work  Force  Planning Project and  the  GAO  study   on  work   force
management, and are  contained  in the Superfund Work Force  Training Resource
Analysis.  OSWER training activities include  detailed task analyses that lead
to  the  development  of curricula for  specific types  of jobs  or subject  areas.
The  curriculum serves  as a tool for planners to use in  determining how to meet
training  needs,  and  for supervisors  to use in determining the  training an
employee needs to improve performance.

     In addition to organizational changes  in OSWER training activities,  other
significant changes occurred in  areas related to Superfund training during FY88,
including:
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     •    EPA Institute:  The EPA Institute was established to focus
          Agency-wide  training  efforts,  and has  made considerable
          progress in  developing  in-house training capabilities and
          expanding  training opportunities.    Coordination  between
          OSWER and the Institute, at both Headquarters and Regional
          levels, will provide  many benefits,  including  support  in
          publicizing  and scheduling training courses.

     •    Technology  Transfer:    EPA's  active  technology transfer
          program is forging new relationships  among EPA,  the states,
          academia, and private  industry.   To  help meet  Superfund's
          technical training needs,  a  series  of Technology Support
          Centers  located  at ORD  laboratories  has  recently  been
          established.  Superfund staff either travel  to  the centers
          to receive training, or  courses developed at the  centers are
          taken  to   the   Regions.     Future  cooperative  training
          development  efforts, as authorized under the 1986 Federal
          Technology  Transfer  Act  (FTTA),  may  include exclusive
          licensing   and   cooperative   research   and   development
          agreements with private firms, universities, or consortia.

     9.4   Management and Information Systems

     Much progress has been made during FY88 in  improving Superfund's management
and  information  systems,   to address  the  increased  demands   for   data and
information.  Positive improvements in the Superfund program's main data  base,
CERCLIS,  include  the   development  of  a local,> personal-computer  network with
direct  access  to CERCLIS,  the  creation  of  both  site-specific  and  non-site-
specific data bases within  the main CERCLIS system, and the establishment of a
CERCLIS user support hotline. The OERR Superfund Directives System, a  data base
designed to track and update various Superfund program documents and directives,
was further modified  and updated.   The  Emergency Response Notification System
was expanded  in  its  data handling and  organizing capabilities  to aid various
response authorities  in the event of  an emergency release.  Improvements were
also made in the data  system containing  technical  information  on many  different
hazardous substances,  to further  assist emergency response personnel in  their
efforts to reduce the  threat of a release.

     9.4.1  CERCLIS

     The CERCLA  Information System (CERCLIS)  contains a  detailed  inventory of
potential  hazardous  waste  sites and  provides  key  data  elements  for the
monitoring  of financial  and  technical  progress of  remedial,   removal, and
enforcement actions.   OERR is  responsible  for  maintaining  and  updating the
CERCLIS data base.  Currently, it contains data on approximately 39,000 sites.
CERCLIS, in its present form, is  the result of the integration of  pre-existing
data bases that no longer  exist  independently.   Since the first generation of
CERCLIS, EPA has  incorporated into CERCLIS  the information from the  following
systems:  the Emergency and Remedial  Response  Information System  (ERRIS), the
Project Tracking System (PTS) , the Superfund  Comprehensive Accomplishments Plan
(SCAP), the Removal Tracking System (RTS), the Case Management System (CMS), and
the Remedial/Removal Financial System Site File.
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     Modifications to CERCLIS

     During FY 1988, progress was made In modifying and updating the operational
status of CERCLIS.   Among the  major  changes  accomplished during the fiscal year
are the following:

     •    Site-specific Data Base:  The site-specific data base became
          fully  operational  in November  1987.    This data  base is
          currently being  used by  all  of the EPA  Regions to store
          information on  particular  hazardous waste  sites within each
          Region.

     •    WASTELAN  (Local  Area Network):    WASTELAN is  a personal
          computer-based version of  CERCLIS  which operates  as a local
          area network data base.  The system became  fully operational
          in Region 4 in November 1987.  It contains all of the core
          data  elements  found  in CERCLIS,   including pre-remedial,
          remedial, removal,  enforcement, and financial,  as well as
          regionally-defined  data elements  for  program  and project
          management.   WASTELAN's data handling capabilities include
          transfer of nationally-required information to the mainframe
          CERCLIS data base, retrieval of financial  information from
          the  Agency's  Financial Management  System  (FMS),  and the
          automatic loading of Superfund milestone data into project
          management software.  The system also allows direct acceiss
          to data by OSCs and RPMs.

          In addition to  the system operating currently in Region 4,
          a trial version of WASTELAN was made available  to all of the
          Regions  for testing  and  evaluation.    Implementation is
          currently underway  in Regions  2,  3,  and 5.  Other Regions
          will  also implement  WASTELAN during FY90 as they complete
          their testing and evaluation processes.

     •    Reports  Library:    This menu-driven  library  of 130  pre-
          programmed  reports  related  to  the Superfund  program and
          contained  within  CERCLIS  was  made   available to  both
          Headquarters   and  Regional   users   in   December  1987.
          Currently, Headquarters and  the Regions are printing more
          than  200 reports a day nationwide.

     •    CERCLIS  User Support Hotline:   The  CERCLIS  user support
          hotline became  operational  in March 1988.  The  hotline is
          staffed 11 hours each day to provide direct support to all
          Headquarters and Regional users, and currently responds to
          an average of 50 inquiries each week.

     •    Non-Site-Specific Data Base:   A non-site-specific data base
          became operational in April 1988.   This portion  of the data
          base, which  is  separate from the  site-specific  data base,
          is  maintained  by  Headquarters and  is used  for Regional
          evaluation.      It   contains   the   SCAP/SPMS  targets  and
          information on Advices  of Allowance for each Region.

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Financial Management System Automated Download into CERCLIS:
In April 1988,  financial commitment, obligation, and outlay
data from  the  FMS could be  loaded directly i,nto CERCLIS.
This is the first time that such a loading of  data has been
done at EPA.

Superfund Progress Report from CERCLIS:  The Agency has been
generating the Superfund Progress Report on a monthly basis
directly  from  CERCLIS,  beginning with the  October  1988
report.  In the past,  the report was compiled from a variety
of  separate  data bases;  the conversion  to an automated,
CERCLIS-generated report reflects the  increased reliance on
CERCLIS and the progress made  in improving the system's data
quality.   As  a result, data  elements  in CERCLIS  that are
used in the report will be updated monthly.

175 RA Candidate  Tracking:  OSWER is currently using CERCLIS
to  track  the  progress and status  of  the 175 RA candidate
starts.   CERCLA  section 116(e)(l)  mandates that remedial
actions at all of  these 175  sites be commenced by October
1989.

Coverage   of   Freedom   of   Information   Act   (FOIA),
Congressional, and Other Information Requests:  EPA can now
respond  to non-recurring  information  requests,  such  as
Congressional  requests and some requests under the Freedom
of Information Act (FOIA).  The use of CERCLIS  for responses
to FOIA requests  may, in many cases, result in little or no
need for additional information or data collection.  In some
instances, though, such as  when FOIA is  used by potentially
responsible  parties   to   request  information  regarding
enforcement sites, CERCLIS is not capable of responding and
other resources are necessary to help  provide  the requested
data.   Data must  now  be  kept up-to-date  on at  least  a
monthly basis, with  both  actual  accomplishment  data and
current planning data covered.  To support  ongoing program
and project management, Superfund managers  are starting to
request  more  frequent  reports  on  program   status  from
CERCLIS.

Monthly Management Reports:   These reports  for OERR Senior
Management  and  Assistant  Administrators  were  developed
during  the  fiscal  year  and  scheduled   for  production
beginning in September 1988.  They provide  a wide range of
program performance data  in areas of  key concern.   For
Assistant  Administrators,  target  and accomplishment  data
will be listed for selected SCAP/SPMS categories including
first  and  subsequent  RI/FS  starts,   first  and subsequent
RODs,  first RD starts, and  first  RA  starts.   Enforcement
target  reporting   includes  RD/RA   negotiations,   RD/RA
settlements,   and   cost  recovery  actions  referred  to
Headquarters.  The reports also will  cover the  status of

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          progress toward beginning 175 RAs by the statutory deadline
          and analyses  of RI/FS  costs  and  duration.    OERR Senior
          Management  will   receive  a  more   extensive  SCAP/SPMS
          accomplishment report, status reports  on Regional advices
          of  allowance,   resource  or  full-time  equivalent  (FTE)
          utilization,  and  the CERCLIS-generated version  of  the
          Superfund Progress  Report.   These reports will increase
          dialogue between Headquarters  and the Regions  on program
          performance issues.

     •    State  Involvement:   OSWER  is  currently entering  into an
          agreement with the  National  Governors' Association  (NGA) to
          determine individual state Superfund information needs and
          current capabilities to meet those needs.  This is similar
          to the work  that the NGA is presently doing for the Resource
          Conservation and Recovery Information System  (RCRIS)  and
          will aid  in the  potential interaction of these two major
          OSWER information systems.

     •    Corps  of Engineers/Other  Federal Agencies:    OSWER  is
          presently working with both  the Corps  of Engineers and the
          Department of the  Interior to determine whether  CERCLIS can
          accommodate their Superfund project management and reporting
          needs.

     Areas for Change in CERCLIS

     Although there have  been many improvements in the  system during  FY88, there
are several problems  that need  to  be  addressed  to  further improve  the system.
Among these critical areas in need of  change are:

     •    Data Quality:   CERCLIS information can be  sorted by many
          different   fields,   such  as  location,  substance,   and
          enforcement  action taken.   A  major problem is that data
          entry is inconsistent and incomplete, with some  fields left
          entirely blank.  This lessens the effectiveness of CERCLIS
          in comprehensive program management reporting.  In response,
          OERR is currently evaluating CERCLIS data in comparison to
          FY87 accomplishments, historical Superfund Progress Report
          data,  and current SCAP targeting/planning data.   These audit
          reports will be sent  to  the Regions on a regular basis so
          that figures can be reconciled.

     •    System Response Time:   Although CERCLIS response time is
          fairly good, it is  slow enough to create discontent.  OSWER
          is  currently  negotiating  with   the   NCC   to   expand  the
          capabilities of its computer hardware  systems and increase
          the systems' response time.

     •    Complexity  of  the  Data  Base:    Regions have   experienced
          difficulties in  writing  reports that  combine   enforcement
          activities  with response  events.    This  is  because  the
          enforcement data is not  organized  by  operable  unit in the

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          data base.  To help solve this problem, OSWER is evaluating
          the potential uses of WASTELAN,  with its  simplified report
          writing features and relational capabilities.  In addition,
          to integrate response events with corresponding enforcement
          activities, OSWER is developing and programming reports for
          inclusion  on  the  CERCLIS  reports  menu  that  serve  this
          purpose.

     •    Report  Availability:    SCAP  and SPMS  reports  were  not
          finalized in time for the Regions  to adequately review their
          data for accomplishment reporting.  Problems in programming
          these reports were corrected and they are now on the CERCLIS
          system menu.

     •    SCAP/SPMS Flags:  Regions are  experiencing difficulties in
          coding all of the proper "flags"  (e.g., first and subsequent
          starts and completions, SPMS targets, and site/event leads)
          in the  data  base so that plans  and  accomplishments appear
          on the official  planning and evaluation  reports.   If these
          plans and accomplishments do not appear on the reports, they
          do not count toward meeting targets.

     •    Data Requests to the Regions for "non-CERCLIS"  data:   Many
          offices are still requesting from the Regions large amounts
          of data that are not contained  in  CERCLIS.  Headquarters has
          set up  focal points for Regional data requests  to assure
          that Regions are not continually burdened with requests for
          available data.

     9.4.2  Strategic Planning and Management  System/Action Tracking System

     The objective of the Strategic Planning and Management System (SPMS) is to
develop  a system of  integrated planning guidance  and  oversight for  program
implementation.   SPMS provides a framework for Headquarters, Regions,  and states
to identify and complete program agendas.

     The Action Tracking System  (ATS)  component of  SPMS  follows the  regulatory
development of  major  regulations,  guidance,  and  policies  for all  programs,
including CERCLA  and  SARA.  OSWER  tracks  the  development  of CERCLA and SARA
guidance  and regulations  listed  in the "Agency Operating Guidance"  and in the
Federal  Register Unified Agenda.    Information  from  the  ATS  can pinpoint
potential or developing problems as regulations and guidance are developed and
implemented.

     9.43  Superfund Enforcement Tracking System

     EPA is presently developing systems  to help improve  the implementation of
Enforcement Program activities.   The  use  of  these  systems will enable  EPA to
more efficiently  target  those  responsible  for  hazardous waste, and  thus help
conserve the Agency's Fund resources.  The Superfund Enforcement Tracking System
(SETS) data base tracks information (e.g.,  names and addresses,  mergers,  etc.)
on the  Potentially  Responsible  Parties   (PRPs)  at  each site.   When a  notice
letter or special notice  letter is  sent to a PRP,  that  PRP's name  is then


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entered directly into SETS.  The  information  received is  then sorted either by
site or  by PRP,  so that  it can be  efficiently used  during the  enforcement
process.

     9.4.4  Case Budget System

     This system tracks  the  enforcement  work  assignment activity and funds for
the  Technical  Enforcement  Support  (TES)  contracts.    It  includes  all  fund
requests, fund  allocations,  and work assignment numbers.

     9.4.5  Cost Documentation Monitoring System

     The Cost Documentation Monitoring  System  (CDMS) supports cost documentation
for section 107 case referrals.   This  data  base contains  detailed summaries of
documented  costs and  the  time  remaining  before  the  statute of  limitations
expires for each particular  cost  recovery effort.

     9.4.6  Financial Management System

     The  Financial  Management  System (FMS)  tracks "accounts  receivable"  by an
individual  PRP for  each  facility  or  site.   Cost  documentation  (e.g.,  time
sheets, travel vouchers, and contractor  invoices) is entered on an optical disk
so that EPA can retrieve pictures of the documents,  rather than just a summary
of the content.  The entire universe of financial transactions in the Superfund
program is recorded in FMS.  This system will be replaced by the integrated FMS
in  January 1989,  but  the  information  held  in  the  new  system will  remain
essentially the same.

     9.4.7  OSWER Internal Directives System

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

     Directives that originate  in, or  are issued  by,  one  of the OSWER offices,
Regional  offices, or other EPA offices,  and affect at least one of the Regional
Waste Divisions or  Environmental  Services Divisions  are considered 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.

     OERR Superfund Directives System

     The  Regulatory and  Special Projects  Section  (RSPS)  in the  Policy and
Analysis  Staff (PAS) is responsible  for managing the OERR segment: of the OSWER
Internal  Directives System.   In managing its  segment of the directives system,
RSPS maintains a hard  copy  file of each document,  tracks  the  development of
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draft directives  (primarily guidance  documents),  and assigns  each a number.
RSPS also works with the originating office to track a document's status, plan
revisions  and  updates, reissue  a document  if necessary,  and  coordinate  the
directives system with OSWER staff.

     A major RSPS  product  in  managing this responsibility  is  the  Catalog of
Superfund Program Directives,  that lists all current OERR policy and technical
and procedural  directives.   The catalog is updated periodically.   Copies of OERR
directives are  available  from the Superfund Docket  or the Public  Information
Center;   reference  copies   are kept   in  the  EPA  Headquarters and   Regional
libraries.

     9.4.8  Emergency Response Notification System

     The  Emergency  Response Notification System  (ERNS)  is  a centralized data
base  containing more  than  70,000 records  of  release  notification  reports
received  from the National  Response Center  (NRC),  EPA Regions,  the U.S.  Coast
Guard's (USCG)   Marine  Safety  Information System (MSIS),  and the Department of
Transportation's  (DOT)  HAZMAT data base.   ERNS  is managed  centrally by  the
Emergency Response Division (ERD), and it is maintained by DOT'S Transportation
Systems Center  (TSC) in Cambridge, Massachusetts.  The Regions receive and input
data to their own respective ERNS on a  continuing basis.

     In October 1986,  Phase I of  ERNS was  implemented.   For the  first  time,
every reported  release of a CERCLA hazardous  substance  was documented  in  one
uniform data base to which all  appropriate agencies had access.  The  information
has been used to provide initial  evaluations  of releases  and to  fulfill request
for information from within the appropriate agencies and  from other interested
parties.  Much  of fiscal 1988 was  spent adding  final  touches to  the  development
of Phase  II  of  ERNS.   A pilot program to  test the system's expanded  capacity
was implemented in Region 6 in early October 1988.  With  the  addition  of Phase
II functions,  the  focus of ERNS  will  shift from being  simply  a warehouse of
information  to  being  a useful  tool   in  verifying and  assessing   information
received at the time of notification.   Phase  II provides  a system for verifying
the  initial  information  received through  a  report,  and  for  describing  the
sources and causes of a release in more detail.  Eventually,  EPA and the other
appropriate agencies hope that ERNS will be used to track  the  entire  lifespan
of a release from notification to clean up.

     During FY88, ERNS  was revised to incorporate consistent methods  of  entering
data into  the  system.   No  systematic  process  of describing  a  release  or  the
quantity  of  a   release  had  previously  been  available.    Thus,  the  Agency  has
developed  conversion   tables  that   translate  the  language  in  which   the
notification was reported into  consistent categories and quantities.  Often when
the NRC or the  Regions  receive notification  of  a release,  the  language  in which
it is reported is not clear  or specific.  For example,  the person reporting  the
release might refer to  "puddles" or "drips."   The conversion  tables allow such
descriptions  to be translated  into   specific quantities,  such as   gallons,
barrels, or pounds.   New notification report forms also have been created  to  aid
in the systemization of data  entry.   When all  data is entered  in a consistent
manner,  searches and sorts of the information are much more easily accomplished.
A person, for example,  could obtain a  list of all  releases of a  certain type of
substance above a specific quantity.  The ability to search and sort  on  a  global

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scale allows the user to access data in a more efficient  manner,  and increases
the usefulness of the system in general.

     The information in ERNS  is used by many different groups.   The Office of
Waste Programs Enforcement's (OWPE) enforcement division  uses  ERNS to identify
PRPs.   Title III personnel  use the system to support  their Accidental Release
Information Program.   The  Toxics  Integration Branch  of  EPA's Hazardous  Site
Evaluation Division (HSED) performs trends analysis  using data from ERNS.   The
Department  of  Transportation also   uses   the  information   to  investigate
transportation-related  releases.   EPA will develop periodic reports that focus
on release trends of oil and hazardous substances.

     9.4.9  Accident Release Information Program

     The Accident  Release  Information Program  (ARIP)  data base  lists certain
non-transportation-related  acute  releases of hazardous  materials  recorded in
ERNS.   The data base includes  information on the  type  of  acute event, when and
where it  occurred,  whether any injuries  or fatalities  occurred,  the  type of
facility or site involved, the  preventative and control measures existing at the
site prior to the  spill, and  the  actions  taken as a result of the spill.   The
data base has a two-pronged objective:   (1)  to create a  national data base of
major spills and prevention techniques used at facilities and sites; and (2) to
provide Regions with data about acute events in their Region  so  that they can
do follow-up inspections or undertake enforcement actions.

     9.4.10 Acute Hazardous Events Data Base

     The Acute Hazardous Events (ARE) data base was  assembled  as  part of EPA's
review of  the  dangers  posed  to  the public and  industrial workers  by sudden,
accidental releases of  toxic chemicals.  The main purpose of  the  AHE data base
is to characterize the  types of events that emit acutely toxic substances in the
United States,  the substances  involved, and the causative  factors  leading to the
release.

     Emphasis in the data base is  placed on obtaining a measure of the scope of
events  rather  than on precisely estimating  quantities  or  frequencies  of
releases.  It purposely is biased toward events considered to  have the greatest
potential for sudden,  large-scale  harm to the populace.  A new coding system has
been applied  to the data  base to  make  it more  quantitative.   Currently,  it
includes quantitative  data  on deaths  and injuries caused by acute events, and
the number  of  individuals  evacuated.   Information  is coded  by  causation and
location of facility.

     9.4.11 Oil and Hazardous Materials Technical Assistance Data System

     The Oil and Hazardous Materials Technical Assistance Data System (OHMTADS)
is  an automated  information  retrieval data  base  containing 126  fields  of
information on  physical, chemical, biological,  toxicological, and commercial
data  on  approximately  1,400  oil  wastes  and hazardous materials  that  are
potentially harmful to  human  health and welfare and the  environment.  OHMTADS
was developed to  assist emergency response personnel  in  identifying hazardous
substances,  the  health  and  environmental   threats   associated  with  these
substances, and the techniques for mitigating hazards  caused  by the release of


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the  substances  during  emergency situations  and at  hazardous waste  disposal
sites.

     Since the passage of CERCLA,  the role of OHMTADS has changed significantly.
SARA mandated that chemical information be made available to the public for all
chemicals on the SARA Title III lists.  During FY88, EPA's OSCs and other expert
users of chemical information systems were interviewed to assist in the revision
of OHMTADS.  The Emergency  Response Division  (ERD)  is currently in the process
of conducting  a needs  analysis  survey  of OHMTADS  to determine  how  well  it
supports OSCs,  what specific changes could be implemented to make it more useful
and cost effective, how it relates to other automated systems that store similar
chemical data, and what relationship OHMTADS may have with SARA Title III.

     9.5   General Rulemakings

     EPA initiated a number of rulemakings during FY88,  including revisions to
the HRS and  to  the  NCP.   The Agency also developed rules  adjusting reportable
quantities for CERCLA hazardous substances and interpreting statutory reporting
requirements for continuous and federally permitted releases.   These and other
rulemakings  initiated by  EPA  are  discussed in  this  section of the Report.

     9.5.1  Revision of the National Contingency Plan and the Hazard Ranking System

     Two of the most significant rulemakings developed by the Agency during the
fiscal  year are  the proposed revisions  to   the National  Oil and  Hazardous
Substances Pollution  Contingency Plan (NCP)  and  the proposed  revisions to the
Hazard  Ranking  System  (HRS).   The  revisions  to  both the  NCP  and  the  HRS
incorporate  the statutory provisions of  CERCLA,  as  amended by SARA.

     9.5.1.1  National Contingency Plan

     Pursuant to section  105  of CERCLA,  EPA has published  a proposal to revise
the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).   The
NCP is the primary regulation directing  government  and  potentially responsible
party responses  to cleanup of releases of  hazardous substances,  pollutants,
contaminants and to discharges of oil.   It outlines  the  steps that  EPA,  the
Coast Guard, and other federal agencies must follow in responding to a situation
in which hazardous substances  or  oil are released or  are likely to be released
into the environment.   The NCP was  first promulgated under section  311 of the
Clean Water Act and was last  revised, under CERCLA, on  November 20,  1985.

     The purpose of  the proposed  revision is  to incorporate new  statutory
requirements and to  set forth  EPA's  revised  approach to  responding  to  the
release of hazardous substances.  Important changes in  this approach have  been
suggested by EPA's experience  in  implementing  the response  program since 1980.
The revised NCP reflects more accurately the  sequence  in which response actions
are  taken  and clarifies  the  roles,  responsibilities,  and activities  of  all
parties involved in a response action.

     The proposed revisions to the NCP address a number of key issues pertaining
to the response programs:
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     Remedy Selection

     For the remedial program,  the proposed revisions  outline  a process whereby
site problems and threats are  identified  and  defined, and a range of remedial
alternatives  is  developed  and  screened.    Promising  alternatives  are  then
analyzed against nine  criteria.   Overall protection  of human health and the
environment,  and  compliance  with   applicable  or  relevant  and  appropriate
requirements  (or invocation  of a waiver)  are threshold  criteria that must be
satisfied in order for an alternative to be  eligible for selection.  Long-term
effectiveness and permanence; reduction of toxicity,  mobility,  or  volume; short-
term effectiveness; implementability; and cost are  the  primary  balancing factors
used to  weigh major  trade-offs  among  alternative hazardous  waste management
strategies.    State and community acceptance  are modifying considerations that
are formally taken into account after public comment is received on a proposed
plan.  After considering public comment and  reevaluating the proposed remedial
alternative relative  to the same criteria, EPA selects the response action.

     Early Action

     The proposed NCP also.encourages and provides  the  opportunity for taking
"early action," i.e., undertaking response activity before or during the RI/FS
process.  Early  actions  are initiated  to contain and/or reduce the  level of
contamination, or to bring hazards at a site  under  control.   Related to early
action  is  the principle  of  "streamlining."   This  principle encourages  the
tailoring of  activities conducted during  the  RI/FS  and  selection of remedy to
the scope and complexity of the site problem.

     Applicable or Relevant and Appropriate Requirements

     Section  121(d)(2)(A)  of CERCLA, as  amended,  requires that, all  remedial
response actions meet  or  exceed state  and federal  applicable or relevant and
appropriate  requirements  (ARARs).    The  proposed NCP  provides  an extensive
explanation of when  provisions of  the  Resource Conservation  and Recovery Act
(RCRA),   as  well  as  other  federal   and  state standards  or  regulations,  are
potential ARARs.   Also,  the proposed  NCP states that maximum contaminant levels
(MCLs)  under the  Safe Drinking  Water Act  will  generally  be   relevant  and
appropriate requirements for the remediation of surface or ground water that is
or may be used for drinking water. Maximum contaminant level goals  (MCLGs) will
be considered where relevant and appropriate,  as in circumstances  in which the
aggregate risk from multiple contaminants or  pathways exceeds 10~4.  The proposal
describes points  in  the  RI/FS process  when  certain types of ARARs should be
identified and provides details regarding the identification  and communication
of state ARARs.

     Role of States

     The proposed NCP  implements the statutory  requirement for more extensive
state involvement through the Superfund Memorandum of Agreement  (SMOA) and the
process of EPA/state  concurrence in remedy selection.   The SMOA  may be used to
establish the general framework  for the EPA/state working  relationship,  to
define the roles and responsibilities of the lead and support agencies, and to
provide general  requirements for EPA oversight.   SMOAs  are intended to ensure
equitable relationships between EPA and states and to reduce misunderstandings


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by clarifying the expectations of both parties.  The process of concurrence will
be  offered  only when a  SMOA  is  established.    EPA  anticipates  that  the
concurrence  process will  increase  EPA involvement  at  state-lead,  non-Fund-
financed sites and will provide  for  greater  state  involvement in the  selection
of remedial actions at Fund-financed sites.

     Statutory Revisions to Removal Action Time and Dollar Limitations

     The  statutory  revisions  to the dollar and  time  limitations on  removal
actions are  incorporated  in  the  NCP.  CERCLA, as  amended,  increased  the  limit
on time that can be spent conducting a removal from six months to one  year,  and
raised the amount of  money that  can be spent for  a removal from $1,000,000 to
$2,000,000.  CERCLA also provided an exemption from the time and dollar  removal
limits when  continued response  is  consistent with the  remedial action  to  be
taken.  The preamble to the proposed revisions also specifies when it would be
appropriate for the  Agency to  invoke  the exemption.  The regulation incorporates
the  statutory   requirement   that  removal  actions  should,   to   the  extent
practicable, contribute to the efficient performance  of  any long-term remedial
action.  The preamble provides guidance on complying with this requirement.   In
addition, the preamble explains EPA's policy that removal actions should comply
with ARARs to the extent practicable.

     Community Relations

      The  proposed  revised NCP  specifies public  participation  requirements,
including conducting community interviews, developing community relations plans,
making proposal  alternatives  available  for  public comment, and  responding  to
comments received.  It also describes the extent to which the requirements  apply
to  the varied  types  of  action taken  under CERCLA.    Public  participation
requirements  vary  somewhat  among  the different types  of  removal  actions
(emergency,  time critical,  and  non-time  critical)  and between removal  and
remedial actions.

     Also, the proposed revisions incorporate the  statutory requirement for an
administrative  record that  contains documents  that   form  the  basis for  the
selection of a  CERCLA response action.  New Subpart  I states  that the record
shall include all documents  that form the basis  of the Agency's  decision when
it selects the response action for  a site.   Subpart I also specifies when  new
documents may be added to  the record after a decision  document  is signed.   The
rule proposes that  the record for remedial  actions shall be available at  the
commencement of  the RI.   The NCP further  proposes that the record shall  be
available for review at a location at or near the site, and  at an office of the
lead agency  or  at another central location  (the  record for  emergency  actions
need only be kept at the central  location).

     9.5.1.2  Hazard Ranking System

     During  FY88,   the Agency  undertook  a  major  revision  of  the  MRS,  the
Superfund pre-remedial tool used to identify sites  warranting consideration for
inclusion on the NPL.  The  proposed changes to  the  HRS will  make it  a more
comprehensive ranking  system, taking into account  two  new exposure pathways  --
the human food  chain and the  on-site pathway,  that considers  among  other
factors,  direct contact with  soils  -- and making  the definition  of "sensitive


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environments" more inclusive.  In addition, the revised HRS will consider both
acute and chronic health  effects.  The revisions will result in a ranking system
that  is  more  accurate   in  assessing  potential   for  exposure,  contaminant
concentration, and contaminant toxicity.   As a result, the HRS will be a better
tool for identifying the most problematic sites.

     The HRS  rulemaking  effort  achieved  several  important  milestones during
FY88,  including:  (1)  workgroup  closure:  (2)  Agency review;  and  (3)  Science
Advisory Board  (SAB)  review.  The  proposed HRS  incorporating Agency  and SAB
revisions was sent to OMB in February  1988  for  review  and  was  proposed on
December 23,  1988.

     HRS Pilot Program

      The Agency  began implementation of the  second  phase of a pilot program
that tests the new and expanded capabilities of the revised proposed HRS.  EPA's
objectives for this pilot program are to  (1)  determine data requirements, cost,
and  time   for   conducting  preliminary   assessments  (PAs),   screening  site
inspections (SSIs), and listing site inspections  (LSIs) under  the revised HRS;
(2) test decision point scores and other evaluation tools  used during the pre-
remedial process  to identify NPL candidate  sites;  and (3) provide information
for PA, SSI,  and LSI guidance documents.

     A Phase  II  project  orientation meeting was held in  June 1988 to discuss
project  objectives,  schedules,  and  work  products.   Subsequently,  the Agency
selected 75 sites on which to conduct PAs,  using the revised HRS process.  SSIs
were  conducted  on 35  of  the   75  sites  and  LSIs  should  be  completed  for
appropriate sites by June  1989.

     Potential to Release Component

     A  major  change to  the HRS  is  the  addition  of a "potential  to release
component" when calculating  the risk to the air pathway.   This addition is the
result  of  statutory requirements,  EPA experience,  public  comments,  and the
Science Advisory  Board's  recommendations.   The scores of  sites will more than
likely rise when the threat posed by a potential air release  is included in the
scoring.

     On-Site Exposure

     The proposed revision includes risks  associated with the possibility of
being  exposed while on the site.   Potential on-site  risks were  riot originally
included when developing the HRS because  the Agency assumed  that threats from
direct  contact  would be  mitigated  through emergency removal actions.   EPA's
experience at NPL sites such as Times Beach,  Missouri, and Mountain View Mobile
Homes, Globe, Arizona, however,  has  shown that at some sites  risks associated
with direct contact or on-site  exposure  still exist after removal actions are
completed.

     Surface-Water Contamination

     The method by which  a score  is  determined for the threat posed by surface
water  contamination  is also  being  changed.    The  revision amends the surface


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water pathway score to include threats posed by contamination of the human food
chain and contamination of water that is used for recreational purposes.   The
updated HRS will evaluate  the possible  effects  on the  aquatic  food  chain of an
actual  or potential  release.   An  EPA study  that included  a  site-specific
assessment involving  12 sites and 27 chemicals verified that  the human  health
risk near some NPL sites can be  significant  due to recreational use of surface
water.

     Human Exposure to Contaminants

     The current HRS evaluates the potential for human exposure to contaminants
at  sites,  but  it  does  not give  additional consideration  when  actual  human
exposure  is  documented.   The current  HRS  also  does  not  differentiate  among
different levels of exposure.  It is oriented toward overall population risk as
opposed to individual risk.   CERCLA  section  105(c) requires  EPA to  assure that
to the maximum extent feasible, the HRS assesses accurately the relative  degree
of risk to human health and the  environment  posed by sites  that are evaluated.
Thus, the  revised HRS  will reflect the potential risk  to individuals  and to
populations  exposed to  actual  contamination.   This will  be accomplished by
attaching more  importance  to  the  ground and surface  water pathways  at  sites
where there is documented proof of the contamination  of wells or drinking  water.

     9.5.2  Administrative Record

     On March 1, 1989, EPA issued an Interim Guidance on  Administrative Records
for  the Selection  of  CERCLA  Response Actions.   This  guidance  reflects  the
proposed revisions  to the  National Contingency Plan (NCP) that were published
on December  21,  1988.   The Agency may refine the  guidance when it  promulgates
the NCP in final  form.   During FY88, the Agency  conducted training in all ten
Regions to ensure  that adequate records are being compiled.  The  Agency also
made presentations to staff of the Department of the Interior and the Department
of Energy on their role in maintaining the  records for  federal facilities under
their jurisdiction.   In FY88,  the Agency established  a basic evaluation and
tracking system to assist  in  the  setting of  priorities for  record compilation.

     9.5.2.1  Purpose of the Administrative Record

     The requirements  for  establishing administrative records form one  of the
key new subparts of the proposed revised NCP.  The administrative  record  serves
two primary  purposes.   First, under CERCLA  section  113(j),  the administrative
record will  serve as  the basis  for judicial  review of  any  clean-up  action.  As
a  result, potentially  responsible  parties  (PRPs)  or  citizens  must   raise
arguments or concerns during the administrative process,  or they will be  barred
from raising them  for the  first time in court.   Record  review also saves time
by limiting  the  scope of any trials to the  contents of  their  written  records,
rather  than  broadening them to  include  oral testimony and  discovery, thereby
saving the Agency's resources for  cleanup, rather than litigation.

     Second,   section  113(k) requires that the  administrative record  act  as  a
vehicle  for  public  participation  in  the  selection of the response action.
Participation by interested persons  ensures  that  the Agency  has considered the
concerns  of  the public, including PRPs, in  selecting  response actions.   The
administrative record includes  documents that form  the basis  for the  Agency's


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action at the site.   The record is compiled as  the Agency receives  or  generates
the necessary response action documents.  Every decision document  is  supported
by an administrative record.

     Without  an opportunity  for  involvement  of  interested  parties  in  the
development of the  administrative record,  persons  challenging a response action
may argue that judicial review should not  be limited to the record.  The Agency
must, therefore, make  the  information that formed the basis for the  selection
of a response action available,  at or near the site to  the public, provide an
appropriate opportunity  for public comment on  this information and  publish  a
notice of its availability in a local newspaper, place  comments and information
received from the public in the record, and reflect  in the record  the Agency's
consideration of this  information.   Documents  generated or received  after  the
decision document is signed are added to the record only if they concern issues
that were specifically reserved or if  they support an amended action memorandum.

     9.5.2.2  Availability of the Administrative Record

     The availability  of  the record  varies  depending  on the  nature of  the
response action.   For remedial  actions,  the record becomes  available  at  the
start  of  the  remedial  investigation/feasibility  study  (RI/FS).    Section
113(k)(2)(A)  requires  the  Agency  to  establish  procedures for  the  appropriate
participation  of interested  persons  in  administrative  records  for  removal
actions.  "Appropriate" participation depends on the  nature of the removal.  The
record for a non-time-critical removal action is available when the engineering
evaluation/cost  analysis  (EE/CA)  is  made  available for  public  comment.   In
contrast,  the record file  for  time-critical removal  actions  is available no
later  than 60  days after the initiation  of  on-site removal  activity.   If
feasible, the record file  for these removal actions  is made  available earlier.
The same procedures are used for establishing administrative records whether or
not the response action  involves  enforcement activity.

     9.53  Reportable Quantities

     The Agency developed  two rulemakings  during  the fiscal  year adjusting  the
reportable  quantities  for specific  CERCLA hazardous  substances.   One rule
adjusts reporting levels for  273 CERCLA hazardous substances,  the  majority of
which  are  carcinogens.   A second rule adjusts  the  reporting levels  of  757
radionuclides.

     The reporting  requirements in sections 103(a)  and (b) of  CERCLA require
that persons in charge of vessels or facilities from which hazardous substances
have  been  released  in  quantities that are  equal  to or  greater than  their
reportable quantities  (RQs) immediately notify  the  National Response  Center of
the release.  Section  102(b)  sets  an  RQ of one  pound for hazardous substances,
except those  substances  for which different RQs have been established pursuant
to  section 311(b)(4)  of  the  Clean  Water  Act (CWA) .    In  addition   to  these
reporting   requirements,  section   304  of  the  Superfund  Amendments  and
Reauthorization Act of 1986 (SARA Title III) requires that  releases of hazardous
substances in quantities equal  to or  greater than their RQs (or one pound if a
reporting  trigger  is not  established by  regulation) be reported  to  state  and
local authorities.
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     Section  102(a)  of CERCLA  authorizes  EPA  to  adjust RQs  for  hazardous
substances and to  designate  as hazardous substances those  that, when released
into the  environment,  may present substantial danger  to the public  health  or
welfare  or  the  environment.    Currently,  there  are  725  CERCLA  hazardous
substances.

     9.53.1 Reportable Quantity Adjustment Final Rule

     The Agency made substantial progress on the  final  rulemaking adjusting the
RQs for 273  CERCLA hazardous substances during the fiscal  year.   The majority
of RQs being adjusted by this rule are RQs for potential carcinogens.   In order
to give the public opportunity to comment, the Agency  published  in the Federal
Register on March 16, 1987, a Notice of Proposed Rulemaking  (NPRM) to adjust RQs
for 273 CERCLA hazardous substances.  Two  final rules  adjusting  the RQs of 260
of the 273  hazardous  substances were published in  August 1989.   RQs  for  four
additional hazardous substances  that were not proposed for adjustment  in the
March  16, 1987,  NPRM  were  also  included  in  these  final rules.   The  four
additional substances are waste streams  that  were listed as hazardous under RCRA
Section 3001 (and, therefore, were designated as hazardous  under CERCLA)  after
the March 16, 1987, proposal was published.

     The Agency adjusted the RQs of the  hazardous substances based on specific
scientific and technical  criteria  that  relate to the possibility  of  harm  from
the release of a hazardous substance  at  certain levels.   The quantity released
is but one  factor considered by  the government  when assessing  the need  to
respond to  such  a  release.  Other factors,  assessed on a  case-by-case  basis,
include,   but are not  limited  to:   (1)  the  location  of  the  release;  (2)  its
proximity to drinking  water  supplies  or other valuable resources;  and (3)  the
likelihood of exposure  or  injury to nearby populations.   The RQ  adjustments  in
this final rule will enable the Agency to focus its  resources  on  those releases
that are  most likely to pose potential  threats to public health or welfare  or
the environment.   These adjustments  will also relieve  the  regulated  community
and emergency response personnel from the burden  of making and responding  to
reports of releases that are unlikely to pose such  threats.

     9.53-2 Radionuclides Reportable Quantity Adjustment

     The Agency also made progress  in  FY88  on the final  rulemaking adjusting the
statutory reportable quantity of one pound  for radionuclides.  Radionuclides are
considered  CERCLA  hazardous  substances  because   they  are  designated  as  a
hazardous air pollutants under section 112 of the Clean Air Act.  Radionuclides
are  comprised  of  approximately  1,500  radioactive  isotopes  whose  release
represents  differing  degrees  of potential harm  to  human  health  and  the
environment.  In the rulemaking, the  Agency  finalized  RQs  for  757  individually
listed  radionuclides,   and  established  an  RQ  o'f  1  curie   for  all  other
radionuclides.  Radionuclide  RQs  are  expressed in units of curies  rather  than
pounds because  curies  are a  more  common unit  of  measurement  for  radiation
protection, allowing for more  timely  reporting and  response, if  necessary.   To
issue  adjusted RQs for radionuclides,  the Agency  developed a new  methodology
that was  presented  for public  comment  in  a notice   of  proposed rulemaking
published in the Federal Register  on March 16,  1987 (52 FR 8172).  The Agency
has revised the methodology  in response  to comments  on the  proposed rule.   The
methodology adjusts RQs for radionuclides based on release scenarios and assigns


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radionuclides to  one  of seven RQ groups:  0.001 curie,  0.01  curie,  0.1 curie,
1 curie, 10 curies, 100  curies,  and  1000 curies.   The final  rule was published
in the Federal Register  on May  24, 1989  (54  FR 22524).

     9.5.4  Federally Permitted and Continuous Releases

     The Agency published two proposed rules that interpret statutory reporting
provisions  during  the   fiscal  year.     The  first  presents   the  Agency's
interpretation of the statutory requirements  of CERCLA section  103(f)(2)  for
continuous releases.  The second proposed rule  presents EPA's explanation of the
exemptions under  CERCLA  section 101(10)  for  federally permitted  releases.

     9.5.4.1  The Continuous Release Proposed Rule

     On April 19, 1988,  EPA published a  proposed rule interpreting the reduced
reporting requirements for continuous releases under  CERCLA  section 103(f)(2).
This rule stipulates  that initial notification of continuous  releases must be
made under section 103(a) to establish the continuity, quantity,  and regularity
of  the  release,  or under  section 103(c)  that requires  notification  to  the
federal government of the existence of certain facilities that are or have been
used for storage,  treatment,  or disposal  of hazardous wastes but do  not  have
RCRA interim  status or  a RCRA permit.   Section 103(f)(2) presupposes  that, in
general, if a release  occurs regularly and  in relatively stable amounts, federal
officials do  not  have  to be  notified each time the release  occurs  to  have the
necessary information to decide whether a response is desirable.   Thus, instead
of reporting  every release as it occurs,  the person  in charge of a vessel or a
facility is allowed to  report less often  for  continuous releases that satisfy
the above criteria.

     9.5.42  The Federally Permitted Release Proposed Rule

     On July  19,  1988,   the Agency published a proposed rule  interpreting the
federally  permitted  release  exemption  from  CERCLA  release  reporting  and
liability provisions.  CERCLA section 101(10)  lists  the  statutes or regulatory
programs  under  which  the exemptions   arise.    For  example,  discharges  in
compliance  with  a  National  Pollutant  Discharge Elimination System  (NPDES)
permit,  releases  in compliance  with  a legally  enforceable RCRA hazardous waste
management facility final permit, or air emissions subject to and in compliance
with permit or control regulations  under  certain provisions of the Clean Air Act
are exempt from the reporting requirements under CERCLA section 103(a) and from
liability for response  costs and  damages due  to  the release (CERCLA section
107(j)).   The proposed rule also  addresses  the  exemption from notification
requirements under Title III of  the Superfund Amendments and Reauthorization Act
of 1986.

     9.5.5  The  Designation Proposed Rule

     During FY88,  EPA's work on a rule proposing to designate  232 extremely
hazardous substances  (EHSs)  listed  pursuant  to  Title  III  of SARA as  CERCLA
hazardous substances  neared  completion.   The rule completed  red border review
and OMB review during the fiscal year and  was  proposed on January 23,  1989.
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     Although  134 substances listed  as  EHSs under SARA Title  III  are already
CERCLA  hazardous  substances,  there  are 232  that  are not.    Currently,  only
releases  of  those EHSs that are also  CERCLA hazardous  substances  are required
to be reported to the  National  Response  Center (NRC).   With the proposed rule,
EPA intends  to reduce  potential confusion concerning the  different SARA Title
III and CERCLA  requirements by ensuring  consistent  procedures for reporting
releases  of all EHSs.   In  addition,  the  January 23,  1989,  proposal  would
facilitate an  expedited determination  of the need for a  federal  response to such
releases.

     9.5.6 Reimbursement to Local Governments

     EPA  published an interim final  rule  to  provide  reimbursement  to  local
governments  for  costs of  temporary  emergency  measures   taken to  prevent  or
mitigate  injury to human health or the  environment.  This regulation is meant
to help  alleviate significant financial burden  on  local  governments for costs
incurred  in   responding  to  releases  or   threatened  releases  of  hazardous
substances.    CERCLA requires,  however,  that reimbursement must not supplant
local funds normally provided for  response.   As of October 6,  1988, only seven
applications had been received requesting reimbursement.  The Emergency Response
Division  (ERD)  is, therefore, investigating whether the eligibility regulations
are unnecessarily stringent.  ERD, however,  has decided to try to publicize the
availability of reimbursement more widely  prior to  revising the rule.

     9.5.7 Technical Assistance Grants

     The Agency published an  interim final rule on March 24, 1988,  that details
the specific requirements for obtaining technical assistance grants  (TAG).  TAGs
are grants of  up  $50,000 that can be awarded by EPA to citizens' group in order
for the groups  to obtain  assistance in  interpreting  information  related  to
cleanups  at  Superfund sites.   The  process  of cleaning  up  a Superfund  site
requires  detailed technical  study of site  conditions  and waste,   analysis  of
methods and techniques for  remediation,  and  decisions based upon statutory and
regulatory  factors.   In  carrying out  these  cleanups,  EPA and   states  seek
informed  comment from  citizens living near  these sites.   TAGS, authorized  by
Congress  under section 117(e) of CERCLA, allow  the citizens to have technical
site information  interpreted  so that they can better understand site conditions
and clean-up   options.    The  citizens  will  thus  be able  to  provide  EPA  with
informed  comment  concerning response  actions to be  taken  at a  site.

     9.5.8 Citizen Awards for Information on Criminal Violations  Under Superfund

     EPA  published on  May  5, 1988,  an interim-final  rule that sets forth the
requirements for obtaining an award  for providing information leading  to the
successful prosecution of any person for  a  criminal violation of CERCLA.  CERCLA
section  109(d),  as amended, authorizes  the  President  to  pay up to $10,000  to
any individual who provides information  leading to arrest and conviction.   This
rule establishes who is eligible for  obtaining an award and who within EPA shall
make the  determination of  eligibility.  The rule also details procedures and
requirements for filing a  claim,  establishes the  criteria  for payment of  an
award,   and provides   an  assurance  of  confidentiality  to those  who  provide
information.   The Agency believes that  the  availability  of cash  awards  will
provide an incentive for individuals  to  report violations  of CERCLA.


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     9.5.9  Other Rulemakings

     The  Agency published  on  August 4,  1988,  a proposed rule  that  would
establish and  govern procedures  for EPA's arbitration of small  CERCLA section
107(a) cost recovery claims.   CERCLA section 122(h)(2) authorizes  the head of
any  department or agency  with authority  to undertake  response action  under
CERCLA to use arbitration as a method for recovering response costs that do not
exceed $500,000  at a facility  (excluding interest).    (If  over  $500,000,  the
Department of  Justice must  concur.)   In  order to use arbitration,  EPA and one
or more  PRP  must agree  to  submit an  issue  or issues arising  in an  EPA cost
recovery claim to an arbitrator for  resolution.

     EPA  published a  final  rule  on  August  22,  1988,  that amends   the  EPA
Acquisition Regulation  to allow the Agency to  employ  other than  competitive
procedures in  obtaining expert services  to be used  in preparing  or prosecuting
a civil or criminal action  under  CERCLA.  The purpose of the final  rule  is to
incorporate  the provisions  of SARA  which authorizes  the  use  of other than
competitive procedures in acquiring  the  services  of experts.
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10.0 MINORITY FIRM PARTICIPATION IN SUPERFUND CONTRACTING

     The 1986 enactment of SARA added to CERCLA a new provision (Section 105(f)
of the amended CERCLA) that requires that the availability of minority businesses
be considered in awarding contracts  for Superfund work.

     The EPA's  Office  of Small and Disadvantaged Business  Utilization (OSDBU)
is responsible for assuring compliance with section 105(f) and has prepared the
following chapter of this Report to satisfy those requirements for fiscal 1988.

     10.1 Identifying Qualified Minority Firms

     EPA employed an extensive program to identify minority firms for potential
work opportunities as either prime contractors or subcontractors  in the Superfund
Program.  In  cooperation with the Minority  Business  Development Agency (MBDA)
of the U.S.  Department  of  Commerce, EPA screened the  MBDA Profile  System to
identify qualified minority firms for potential contracting opportunities.  The
Profile  System  includes  all  minority   firms   from  the   Small   Business
Administration's  Procurement  Automated Source  System   (PASS).   Through  this
search, OSDBU identified 268  minority  contractors having  Standard Industrial
Classifications (SIC) codes that would lend  themselves to the Superfund Program.
OSDBU  contacted these  268 firms individually  by letter to inform  them of the
contracting  and training opportunities available under Superfund.   The  U.S.
Postal  Service  returned more  than 50  percent of the  letters.  Twenty firms
responded to the Agency's informational  letters, and most of  these firms attended
the  EPA.-sponsored   Superfund   Training  Program  conducted  by  the  National
Association of Minority  Contractors  (NAMC).

     A  number  of  firms  contacted  the  OSDBU  independently,   inquiring  about
contracting  opportunities.    Some   of  these  firms  have   the  Small  Business
Administration's (SBA) Section 8(a)  Certification and, where possible, OSDBU has
screened these  firms for future consideration.

     10.2 Efforts to Encourage Participation

     EPA has also attempted to bring qualified  firms into the Superfund minority
contracting program  in  several other ways.

     Hazardous  Waste Cleanup Training Program:  On January 14, 1988, EPA entered into a
contract with the NAMC to conduct hazardous waste cleanup  training programs, with
a potential value of $500,000.  The NAMC conducted training in four cities (New
York,  NY,  Columbus,  OH, Los  Angeles,  CA, and Dallas,  TX) .  The  training was
directed toward small  and  minority businesses.   Of the  total enrolled  (134
individuals  represented 100  firms),  127 individuals represented  95  minority
firms.  The  training consisted  of  a Superfund orientation and information on
safety and health and procurement,  and  was  designed to  make the firms eligible
for contracting opportunities  in the hazardous waste  clean-up program.

     State Information Seminars:   In  FY88,  two  minority  business enterprise (MBE)
conferences were held:   one  by the State of Mississippi, and  the  other by the
States  of  Maine, Vermont,  and  New Hampshire,  jointly.   The  purpose  of  the
conferences was to familiarize  MBEs with contracting  opportunities  available
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under Superfund.   Representatives from approximately 150 firms  attended these
conferences.

     Also, EPA signed State Cooperative Agreements with the States of Washington
and  New Jersey  enabling these  states to conduct  State MBE/Women's  Business
Enterprise  (WBE)  Information Seminars.  These seminars were  planned for FY88,
however, due to  administrative  difficulties  they were  rescheduled.   Currently,
the New Jersey  seminar is scheduled for April 1989  and  the Washington seminar
is scheduled for  later in FY89.

     Because  of  the   success  of the  state  seminars,  EPA will sponsor  four
additional seminars in Georgia, Ohio, Louisiana, and California.  Scheduling is
dependent upon the availability of funds and the award of cooperative agreements.

     Minority Procurement Conferences:  OSDBU,  in cooperation with EPA's Procurement and
Contracts  Management  Division,   sponsored  a highly  successful conference  in
Cincinnati, Ohio.  Representatives of approximately 150 minority firms attended.

     Special Meetings with Major Superfund Prime Contractors:  EPA held special meetings with
the  major  Superfund prime  contractors in an  effort to  increase their  use  of
minority business subcontractors.   As  a result of  these  meetings,  EPA  will
implement  outreach programs  that identify  minority firms for  subcontracting
opportunities, develop policy guidelines to promote subcontracting activity with
minority firms, establish a vendors' information system to identify prospective
minority  firms  for  bid  solicitations,  and establish  procedures   to  debrief
unsuccessful minority  bidders.   These  special meetings  appear to be effective,
as subcontracting work conducted by minority firms  on these major contracts is
increasing.

     Congressional Workshops for Superfund Program :   At the request of U.S. Representative
Mervyn  Dymally,   OSDBU   and  the  Contracts  and  Procurement  Division  staff
participated in  a Procurement Conference conducted  in Carson  City,  California,
in February 1988.  OSDBU used this conference  as  an outreach  opportunity to
advertise  the   EPA   Superfund  Training  Program   for   minority  contractors.
Representatives  of approximately 200 firms attended this workshop.

     At the request of U.S.  Representative John Lewis,  OSDBU  participated in a
workshop  conducted in Washington,   D.C.,  in June  1988,  to  discuss Superfund
opportunities  with the  Atlanta  Business  League.    Over 50  minority  business
persons attended the  workshop.

     OSDBU Training Workshops:  OSDBU conducts  MBE/WBE  Training  Workshops for EPA
Regional, state, and local officials. OSDBU held workshops in  seven EPA Regions,
involving 39 states, with approximately 350 officials in  attendance.  OSDBU also
conducted special Superfund workshops  in two Regions,  involving 14 states, and
in response to a special request by the State of California, conducted Superfund
training in Sacramento in September 1988.

     OSDBU Superfund Listing of Minority Contractors:  During the fiscal year,  OSDBU began
to identify qualified  minority  contractors for possible Superfund opportunities
in the  future.   OSDBU has retained  the names of all individuals and firms who
attended  the  Hazardous Waste  Cleanup  Training Program and has  contacted each
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individual  and/or  firm  to  develop capability  statements  for  use  in  future
Superfund work.   OSDBU will maintain the listing and make  it available  to all
interested  sources,  including,   but not  limited  to,   EPA's Procurement  and
Contracting Operations nationwide, major prime contractors doing Superfund work,
state authorities  conducting Superfund operations, and  other federal agencies
and departments.

     MBDA Annual Conference:  In August 1988, MBDA conducted its annual conference
that  included  representatives  from  MBDA  regional  offices  and all  Minority
Business Development Centers (MBDC).  EPA was  invited to have a special session
involving minority  contractor utilization in  Superfund work.  A special team of
EPA personnel presented all attendees with an  overview of the  Superfund Program.
EPA also  asked the MBDC  representatives to  identify potential  candidates for
training and procurement  opportunities.

     OSDBU Annual Workshop:   The  OSDBU  annual MBE/WBE workshop  took  place  in
Dallas, Texas, on April 12 and 13, 1988.   The principal emphasis of this workshop
was to establish  the need for greater minority contractor participation in the
Superfund Program.

     Letters to Other Federal Agencies Participating in the Superfund Program:   OSDBU sent letters
to other  federal agencies  and  departments that participate in  the  Superfund
program.  The  letters  stress the  importance of the  use  of minority contractors
in any procurement  activity that is funded by Superfund monies.   This was the
second successive  year that OSDBU has emphasized the importance  of the  use of
minority  contractors  and also  the  importance  of  timely  reporting of  such
utilization for  incorporation into  the  Report to Congress.   The  dollar amounts
that went to minority  contractors in FY88 are small.   In an effort to increase
the dollar amounts, OSDBU is planning to meet with federal  agencies  that have
the largest expenditures  under  Superfund interagency agreements  in an attempt
to increase the number of contracts and subcontracts  that these  agencies place
with minority  firms.

     Publications of Superfund Participation:   EPA  has issued  a number  of publications of
interest to minority contractors,  including:

     •    The New Superfund -- What It Is, How It Works,  August 1987;

     •    Superfund [WH/FS-87-001R],  Fall 1987;

     •    The  Superfund Remedial  Program [WH/FS-86-002R],  Fall 1987;

     •    The  Superfund Removal Program [WH/FS-86-003R],  Fall 1987;

     •    Public Involvement in  the Superfund Program [WH/FS-86-004R] ;
          Fall 1987;

     •    Identifying  Superfund Sites National Priorities List (NPL)
          and Hazard Ranking System (HRS) [WH-FS-86-005R], Fall 1987;

     •    Environmental Response  Team [HW 2], April 1984;
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     •    Minority  Firm  Participation for Superfund Contracting,
          Fiscal Year 1988;

     •    The Superfund Enforcement Process:   How It Works, Summer
          1988;

     •    State and Local Involvement in the Superfund Program [WH/FS
          88-009], Spring 1988; and

     •    Superfund Innovative Technology Evaluation  (SITE) Program,
          November 1988.

     The greatest dollar value  of minority firm work on Superfund projects is
represented by EPA's direct procurement.   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 minority firms are listed below:
     Professional               Field Support              Construction
Health Assessment            Drilling/Well            Site Clean-up
Community Relations          Installation             Excavations
Feasibility Studies          Laboratory Analysis      Waste Hauling Disposal
Data Management                                       Security
Geophysical Surveys                                   Site Support; Facilities
Remedial Investigations
Expert Witness
Editing
Air Quality
Monitoring
     CERCLA Cooperative Agreements:   Cooperative  agreements  (CAs)  are. contractual
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.  Funding  is  on a
shared basis.  Governments with CAs may establish more specific subagreements,
provided  that   such   subagreements   are   for  procurement  activity.     Each
subagreement,  however, must  have  a  negotiated "Fair  Share"  objective for
minority business participation.   EPA and the state may agree to negotiate  an
overall "Fair Share"  objective  for total  state  projects for a fiscal year,  or
they may negotiate individual "Fair Share" objectives on a  site-by-site basis.
In  either  event,  minority  businesses  must  be  given   the  opportunity  to
participate and  the governmental agencies must  carry out the affirmative  steps
specified in EPA Regulations  to maximize  minority business participation.   In
FY88, EPA awarded 213 CAs  amounting  to $124,934,404.   The CAs were either new
requirements,  continuations,  augmentations  (increases),   or revisions.   The
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states awarded  25 subagreements  to  minority contractors with a potential value
of $41,459,225.

     EPA  Interagency Agreements'.    Interagency  agreements  (lAGs)   are  similar  to
cooperative  agreements,  except that they are negotiated between  EPA  and other
federal agencies that  perform functions related to Superfund work  such as the
U.S. Army Corps of Engineers.  These agencies use their own procurement methods
when entering into contracts for services to be provided in accordance with the
IAG.  Interagency transfers of Superfund monies amounted to 174 transactions for
a  sum total  of $172,048,292.   Like  the  CAs,  the  lAGs were  for either new
requirements,  continuations,  augmentations,  or revisions.   Federal  agencies
awarded  eight  procurement  actions  to  minority contractors  for  a  total  of
$1,447,779.

     As mentioned previously, EPA is planning to meet with federal agencies who
receive the  bulk of IAG  monies  from Superfund.   In FY88,  the Corps  received
$46,899,785 under Superfund lAGs. Of this amount, the Corps placed one contract
worth $68,000  with  a minority firm.   EPA will  attempt to  find ways  in which
agencies, such  as the  Corps, can increase their utilization of minority firms
in their contracting operations  for Superfund.

     EPA Direct Procurement:   EPA direct procurement resulted in by far  the largest
dollar volume that was  placed with minority  firms  in FY88.   The  Superfund
Program awarded a  total of  3,947 contracts  during the fiscal  year,  the total
amount of  dollars  placed  under  these contracts was  $613.3 million.    Of this
total, minority awards were  made as  follows:
                                                     Total  Dollars
               Type of Contractor        Number      (in millions)
Minority Prime Contracts
SBA 8 (a) Contracts
Minority Subcontracts
38
349
103
$ 7.4
$21.8
$ 9.8
     Total minority  contracting was  $39  million or  6.3  percent of the  total
dollars obligated  for  Superfund in FY88.  Not  included in these totals  was  a
contract using Superfund monies awarded to the NAMC,  in the amount of $500,000.
These dollars are  not  included in the above totals since NAMC  is a  non-profit
organization.
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11.0 TECHNOLOGY-RELATED RESEARCH AND DEVELOPMENT

     11.1 Overview

     Section 301(h)(l)(D) of CERCIA requires the Administrator of EPA to submit
as part of the Report to  Congress an evaluation of newly developed feasible and
achievable permanent treatment technologies.  SARA emphasized selecting remedies
that, in addition to being  protective  of  human health and the environment and
cost-effective,   utilize  permanent   solutions   and   alternative   treatment
technologies,  or recovery  technologies  to the  maximum extent  practicable.
Remedy  selection  decisions  should  also  take   into  account  the  statutory
preference for remedies that employ treatment that permanently  and significantly
reduces  the  toxicity,  mobility,  or volume  of  hazardous substances  as their
principal  element.   The  Superfund research and  development program  has  the
responsibility of developing innovative technologies  that  can  help EPA meet the
statutory requirements and preferences  for remedy selection.

     The Superfund technology development  and evaluation program is divided into
two  major areas:    the  development  and performance  of  unproven  treatment
technologies, and the Superfund Innovative Technology Evaluation  (SITE) Program.
The  first  area evaluates the performance of unproven  treatment  technologies
developed by EPA and the  private  sector, and develops treatment technologies to
the proof-of-concept stage,  so that through the SITE  Program and application of
the  technology  transfer  program, the  private  sector can make  the  technology
commercially available.  The overall goal  of the SITE Program is  to maximize the
use of alternative technologies in cleaning up Superfund sites and to encourage
the development and demonstration of new,  innovative technologies.

     The treatment technology research  program emphasizes the development of new
and  innovative  treatment technologies  to either  the pilot-scale  or proof-of-
concept stage in preparation  for-full-scale field demonstrations.   Through the
program,  staff  evaluate the cost  and  performance of  available  treatment
technology when there  is low  commercial interest, low potential for profit, or
high economic risk associated with development of the technology.

     The  evaluation of  treatment  technologies   is  to  indicate  areas where
research advanced in FY88,  including in-situ extraction, in-situ degradation or
detoxification,  in-situ  immobilization,   and   best  demonstrated  available
technology (BDAT).

     During  the  fiscal  year,  the  SITE program   continued  its  work  with  the
demonstration  of  new  measuring and  monitoring  technologies  to  assist  in
Superfund  site  characterization.   The SITE technology  demonstration program
distributed a new round of solicitations to the private sector for proposals to
develop and demonstrate new  technologies applicable to most or all steps  of site
cleanup.   Also,  SITE'S  technology transfer program expanded  its  efforts to
communicate SITE information  to all members of the public.

     EPA's  search  for  better  cleanup  technologies  extended  to  overseas
developments  in FY88.   Site visits  to  cleanup projects  in  Europe  yielded
valuable information concerning directions taken  and  progress made in hazardous
site investigation and remediation activities.
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     The Agency  also has  encouraged research to support the Superfund program
at higher institutions  of  learning.  The Superfund Research Grants program funds
development  of  new biological  and  chemical cleanup  approaches.    Designated
university hazardous substance research centers study  problems relating  to  the
generation, transportation, and disposal of  hazardous  and  toxic  wastes.

     Finally, through the  Superfund Technology Support Project (TSP),  the  Agency
provided more resources, including technology experts,  to assist field staff  who
are directly responsible  for  the  management and cleanup of toxic  waste  sites.
TSP also includes better  training  and career enrichment for RPMs and OSCs,  the
professionals most responsible  for overseeing actual day-to-day  operations  at
Superfund sites.

     11.2 The Superfund Innovative Technology Evaluation Program

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

     There are five components to  the Agency's  SITE  program:

     •    The demonstration program;

     •    The Emerging  Technologies  program;

     •    The Innovative  Development and Evaluation  program;

     •    The  Measurement  and  Monitoring  Techniques  Development.
          program; and

     •    The Technology  Transfer/Clearinghouse program.

A detailed description of the SITE program will be presented  in the annual SITE
Program and Accomplishments Report.

     11.2.1  The Demonstration  Program

     The purpose of  the demonstration and evaluation  of selected technologies
under the  SITE  demonstration  program is to  develop  data on performance, cost-
effectiveness, and reliability  so  that  Superfund  decisionmakers  can  make sound
judgments  about  the  applicability of a technology to  a particular  site.   The
results of the demonstration should identify the limitations  of the technology,
the wastes  and media to which it  can be applied,  the operating procedures,  and
the  approximate capital  and  operating costs.   The  demonstrations   should  be
carried out at full-scale, or  at a scale that allows valid comparison and direct
scale-up  to commercial size units.    The  duration of the  demonstration  is


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determined on  a  case-by-case basis, but it must  be of a sufficient length  to
adequately characterize equipment reliability and operational variabilities.

     SITE demonstrations are usually conducted at actual uncontrolled hazardous
waste  sites,   including Superfund  sites.    Occasionally,  demonstrations are
conducted at EPA-operated  test and  evaluation (T&E) facilities.  At these T&E
facilities, technologies can be evaluated over a wide range of operation without
releasing pollutants  outside the facility.  The  tests are conducted  in  these
facilities using  synthetic  wastes and wastes  brought in from actual hazardous
waste sites.

     Under the demonstration program,  EPA  and the developer of the technology
share the cost of funding technology demonstrations.   The  technology developer
pays the costs of erecting  and operating the equipment onsite and of dismantling
and removing the  equipment  at the end of  the  demonstration.  EPA pays for the
costs  of  sampling  and  analysis,   quality  assurance  and  quality   control,
evaluating data, and preparing reports.  EPA may also help the developer obtain
any required permits.   At the completion of a successful demonstration,  EPA will
undertake  activities   to  encourage  wide-scale  use  of the  technology in the
Superfund program.

     EPA  issued  a  third  request  for projects  under  the  SITE demonstration
program  in  January  1988.    From   applications  received,  EPA  accepted   10
technologies,  bringing the  total  number  of  accepted  technologies  under the
demonstration  program to   29.     Exhibit* 11.2-1   lists   these  10   accepted
technologies  and their developers, along  with  an anticipated demonstration
completion date where  available. EPA issued a fourth request for projects  under
the demonstration program in January 1989.

     Also in FY88, six field demonstrations were completed for new technologies
under  the  demonstration   program.    These  demonstrations  included   infrared
incineration,  solidification,   in  situ  vacuum  extraction,   oxygen-enhanced
incineration, and solvent extraction.

     11.2.2 The Emerging  Technologies Program

     The goal  of the  Emerging Technologies program (ETP)  is to ensure that a
steady stream  of  more permanent cost-effective technologies will be ready for
demonstration  in the field,  thereby  increasing  the  number  of  alternatives
available for use in Superfund removal and  remedial actions.  EPA initiated ETP
in FY88 by soliciting  pre-proposals  to  further develop and test (at pilot-scale)
technologies  that had  been proven at  bench-scale  or  laboratory-scale.   The
Agency received a total of  84 pre-proposals from this solicitation.  EPA invited
15 of  those who had  submitted pre-proposals to  submit cooperative agreement
applications  to  EPA's  Grants  Administration  Division.     EPA  received   12
cooperative agreement applications  and selected seven  for  funding.  Exhibit
11.2-2 lists  the  seven participants and the ETP  technologies.   Four  of  these
technologies involve  aqueous  treatment of metals  or organics  and three involve
soils treatment of metals or  organics.

     EPA issued a second ETP  solicitation  in the  summer of  1988.  The  emphasis
in this  solicitation  was on the treatment of  complex mixtures of pollutants
(organics and  inorganics) in soils  and sludges.   EPA will  award six to eight

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            Progress Toward Implementing Superfund:  Fiscal Year 1988
                              Exhibit 11.2-1
             Technologies Accepted  Under the Site
             Demonstration Program  for Fiscal 1988
Developer
 Technology
Demonstration Completed
     (Anticipated)
Biotrol, Inc.
Chaska, MN

Biotrol, Inc.
Chaska, MN

CBI Freeze
Plainfield, IL

Chemical Waste
Management, Inc.
Riverdale, IL

Detox, Inc.
Dayton, OH

E.I. DuPont de
Nemours, Inc.
Newark, DE

Freeze Technologies Corp.
Raleigh, NC

Silicate Technology Corp.
Scottsdale, AZ

Toxic Treatments, Inc.
San Mateo, CA

Ultrox International, Inc.
Santa Anna, CA
Soil Washing
Biological
Degradation

Separation By
Freezing

Low-Temperature
Desorption
Fixed-Film
Biological

Microfiltration
Separation By
Freezing

Pozzolonic/
Silicate Based

In situ Steam/
Air Stripping

Ultra-violet
Radiation and
Ozone
   (Spring 1989)
   (Spring 1989)
   (Spring 1989)


   (February 1989)


   (March 1989)
SOURCE:  OSWER Annual Report:  Fiscal Year 1988. OSWER, November 1988.
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                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                   Exhibit 112-2
              Emerging Technologies Program Participants
           Developer
      Technology
     Atomic  Energy  of  Canada Limited
     Research,  Inc.
     Chalk River, Ontario

     Battelle Memorial Institute,
     Columbus Division
     Columbus,  OH

     Bio-Recovery Systems,  Inc.
     Las Cruces, NM

     Colorado School of Mines
     Golden, CO

     Energy  and Environmental
     Engineering, Inc.
     Somerville, MA

     Envirite Field Services,  Inc.
     Atlanta, GA

     Western Research  Institute
     Laramie, WY
Ultrafiltration
In situ Electroacoustic
Decontamination
Biological Sorbtion
Wetlands-Based Treatment
Laser Stimulated Photochemical
Oxidation
Solvent Washing


Contained Oil Recovery of Wastes
     SOURCE:  OSHER Annual Report:  Fiscal Year 1988, OSWER, November 1988.
cooperative agreements under this solicitation, depending on the level of funding
requested by the cooperative  agreement  applicants.

     1123  Innovative Development and Evaluation Program

     The purpose of  the  SITE Innovative Development  and  Evaluation program is
to test, evaluate, and demonstrate promising technologies  that can be used to
clean up uncontrolled hazardous waste sites.   These  are technologies that have
been  developed under  the  Office  of Research  and  Development's  (ORD)  basic
engineering  research  program and that  show potential  for  commercial  use.
Currently,  ORD  is  developing technologies  at bench-,  laboratory-,  and pilot-
scale level for use at Superfund sites.   Full-scale and pilot-scale evaluations
of promising technologies  will  take place at actual  Superfund sites  or at EPA
Test  and  Evaluation  Facilities.    Activities scheduled  under  the  Innovative
Development and Evaluation  program for  FY89  include:
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     •    Demonstration  of a  mobile  carbon regenerator  that  wilL
          detoxify and  regenerate  contaminated carbon and provide  a
          safe and effective method for handling contaminated carbon;

     •    Demonstration of  a mobile soils washer that will  separate
          contaminants  from soil by high  energy mixing of soils and
          solvents, additives, surfactants,  acids,  and bases;  and

     •    Field  testing of potassium  polyethylene  glycolate  (KPEG)
          technology, which is an effective dehalogenator of  aromatic
          and aliphatic organic  materials, including PCBs and other
          toxic halides.

     112.4 Measurement and Monitoring Technologies Development Program

     Another component of the SITE  program is the  development and demonstration
of new  and innovative  measurement and monitoring  technologies that will  be
applicable to Superfund site  characterization.   The Management  and Monitoring
Technologies Development program has four  major 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

     •    To monitor  the success  or effectiveness  of the  selected
          remedy.

     Under this  program, EPA's  Environmental Monitoring Systems Laboratory  in
Las Vegas, Nevada,  (EMSL-LV)  supports  the development of improved  measurement
and monitoring  techniques  in  conjunction with  the SITE program.    EMSL-LVs
research  and  development  focuses  on  two  areas of  monitoring and  measurement
technology:  immunoassays  for  toxic substances and fiber optic  sensing  for  in
situ analysis  at  Superfund sites.   In FY88,  EMSL-LV continued its work  on
developing these two monitoring and measurement technologies.

     112.5 Technology Transfer/Clearinghouse Program

     Recognizing  that  access  to  treatment information  is   essential  to  the
acceptance and use of alternative  technologies,  the  SITE program  developed a
Technology  Transfer/Clearinghouse  program  that collects,   synthesizes,   and
disseminates technology performance data.  Originally only a clearinghouse for
SITE program projects, the Technology Transfer/Clearinghouse program is evolving
into a  center that houses  a variety  of  information on  existing,  as well  as
emerging, hazardous waste treatment technologies.

     The clearinghouse has  three components:

     •    A hotline to  provide  callers with information on  remedial
          technologies;
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     •    An  electronic bulletin board  system  (BBS)  that  fosters
          communication and technology transfer among Regional and EPA
          Headquarters  staff  who are involved  in solid  or  hazardous
          waste   regulation,    permitting,   or  enforcement;   (ORD
          scientists and engineers at  Headquarters  and laboratories,
          which are  supporting OSWER,  also can use BBS.  The  BBS is
          designed to be easy  to  operate  and readily  accessible from
          anywhere  in  the  country.    It  is  a forum for  technical
          interchange at the working level that enables staff members
          to  establish and maintain  contacts  with counterparts  in
          other Regions, offices, and  laboratories.);  and

     •    A  collection of  reports,  journals, and other  documents
          housed  in the  EPA  library's  Hazardous Waste  Collection.
          (This collection is  available at EPA's ten Regional and five
          laboratory  libraries.   The bibliographic  data  base  is
          accessible using a personal  computer.)

     In  FY88,  the  Technology  Transfer/Clearinghouse   program  developed  a
centralized  data  base  to  assist OSCs  and RPMs  in answering  questions  about
available hazardous waste technologies appropriate for remediation at sites for
which they are or will be responsible.

     113 International Survey of Treatment Technologies

     To ensure  that Superfund  sites are  addressed using the  best  technology
available  world-wide,  EPA completed  an international  survey  of  treatment
technologies.    The  purpose   of the  survey was  to   identify  and  assess
internationally-used  treatment technologies that  are applicable  to hazardous
site remediation in the United  States.

     In  Phase I  of  the  survey,  EPA  identified  95  treatment  technologies.
Fifteen of these technologies  were selected for further study in Phase II of the
survey.   Belgium,  the  Federal Republic  of Germany,   and the  Netherlands  are
employing especially promising  technologies, including:

     •    Soil washing;

     •    Biological treatment;

     •    High temperature slagging  incineration;  and

     •    In  situ  vacuum  extraction  of  volatile organic  compounds
          (also well-known in  the United States).

A complete description of the results  of  the International  Survey is contained
in  Assessment  of   International  Technologies  for  Superfund   Applications
(September 1988, EPA/540/2-88/003).

     11.4 Research Grants/University Hazardous Substance Research Centers

     EPA conducts several  programs  with the nation's  universities to research
topics  related to  Superfund  site   assessment and  cleanup.   The  University

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Research  Grants program,  established  in FY87  continued  its work in  FY88.
Applications  were  solicited in  March 1988  for  "innovative,  cost-effective
methods for the treatment of hazardous wastes in  situ  at Superfund sites".  In
response  to this  solicitation,  EPA received 26 applications  and  funded eight,
following external peer review.

     Section  311(d)  of CERCLA  authorizes  $5 million  annually  for  EPA  to
establish at least five, but not more than ten, university  hazardous substance
research  centers  (HSRCs) around the country.   The Agency's  FY88  appropriation
included  $5 million  for this program,  provided that no  more  than five  centers
be established, and that these centers be competitively selected.  The HSRCs are
required  to  conduct long-term  and short-term research,  as well  as  providing
training  and  technology  transfer  relating  to problems associated with the
manufacture,  use,   transportation,  disposal,  and  management  of  hazardous
substances.

     11.4.1 University Research Grants  Program

     The  following  is  a  representative  sample  of  the kinds of  University
Research Grants program projects that EPA funded:

     •    More  effective  anion-exchange  resins  to   remove  toxic
          contaminants  in ground water at Superfund  sites;

     •    Enhanced   microbial  degradation  of  hydrophobic  organic
          contaminants  at sites;

     •    Use of enzymes from genetically engineered micro-organisms
          to dechlorinate PCB in soils at Superfund  sites;  and

     •    Development of a portable, fixed-film decontamination unit
          to enhance biodegradation of contaminants  in ground water.

     Funding for  these  projects totals $1.42 million,  to be  disbursed over a
two-year period.  EPA used an additional $0.85 million to fund continuations of
grants awarded  during the previous  two years.

     11.4.2 University Hazardous Substance Research Centers

     EPA  published a solicitation  for proposals  for HSRCs  on  March 22,  1988.
To  ensure  equitable geographic  distribution  of these centers,  the  Agency
partitioned the country into five "region-pairs" and will establish one HSRC in
each region-pair.  Each HSRC must  focus its research on problems of particular
concern  to  the states  in its  region-pair.   The  following  region-pairs were
established:

     •    Regions  1  and 2  (New England, New York,  New  Jersey, Puerto
          Rico, and  the Virgin Islands);

     •    Regions  3  and  5  (the  mid-Atlantic  and  the  Great  Lakes
          States);

     •    Regions  4  and 6  (the  South and  Gulf  Coast  States);


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     •    Regions 7 and 8 (the plains and Rocky Mountain States) ;  and

     •    Regions 9 and 10 (the Pacific Coast States, Arizona,  Nevada,
          Idaho, Alaska,  Hawaii,  and Guam).

The deadline for submission  of proposals  was June  27,  1988.

     EPA received proposals  from 33 institutions or consortiums,  representing
95 colleges and universities.  Five panels consisting of at least  10 scientific
and  technical  experts   from  outside  the  federal  government   reviewed  the
proposals.   These  five panels will  make  their recommendations for  funding to
EPA's Assistant Administrator for  Research and Development,  who will be  the
final decision official.   EPA  will invite the  chosen institutions  to  submit
formal  applications for  assistance.   These applications  should be  received,
processed, approved, and  funded  in  FY89.

     11.5 Technology Support Project

     In response to an  increasing need  to manage hazardous waste  problems with
the most effective  support systems  available,  and  in response to  Congressional
and General Accounting Office (GAO)  recommendations,  OSWER  and ORD began to work
jointly to develop a comprehensive approach to technical management of Superfund
sites.  EPA initiated such a program in FY87:   the  Superfund Technology Support
Project.   The  project was designed  to  provide EPA personnel, state  Superfund
organizations,  PRPs,  and  the public with  technical  assistance, demonstration,
training,  and  information   about   the   best   demonstrated  technologies  for
application at  Superfund  sites,  as  rapidly as  possible.  In FY88,  TSP assisted
field management personnel with  a network of numerous resources  in both  OSWER
and ORD.

     The TSP includes four ORD Superfund Technology Support Centers, which will
provide RPMs and OSCs in  the field with:

     •    A technology  transfer/information clearinghouse;

     •    Career enhancement and development;
     •    Site  technical  reviews;
     •    Contractor assistance;  and
     •    High-technology demonstration/training.

These four  Technology Support Centers are located at  ORD laboratories in  Las
Vegas,  Nevada,  Cincinnati,  Ohio, Athens,  Georgia, and* Ada, Oklahoma.    The
activities  that EPA initiated in the  first two areas of  the TSP in  FY88  are
described below.

     11.5.1  Technology Transfer/Information Clearinghouse

     As an example of  the  Agency's efforts  to transfer technological information
to field managers,  the Office of Program Management and Technology  (OPMT)  in
OSWER has been developing a  new analytical ground-water computer  system.   The
objective has been to develop a computer workstation that combines commercially
available  geologic  interpretation  software with  field data.   The  resulting


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workstation will provide lucid graphics, more efficient information storage,  and
data  interpretive  aids  for  analyzing  ground-water  problems.    It is  OSWER's
intention to provide one complete workstation, including training and continuous
technical support,  for  RCRA and CERCLA  program use in  each Region.

     Four Regions  have  had  computer  workstations  since  October  1987.    The
workstations have been undergoing a series of debugging and trial runs  and OSWER
now believes that the system has been adequately refined for installation in the
remaining Regions.   Success in each of the Regional offices will depend upon the
cooperation  of  all  personnel  and  will  be  measured  by:     (1)   effective
installation, training,  and staff use;  and (2)  a nationwide network  of system
users that can begin to  share expertise and contribute  to the  evolution of  the
system for improved ground-water  analyses.

     11.52 Career Enhancement and Development

     In 1987, the Agency began  to address the importance of the need for full
career development  for  personnel  in the  critical  positions  of  OSC  and RPM.
Congress and  the General Accounting Office  (GAO)  also identified the  need to
address Superfund workforce and staffing problems.  A GAO report to Congress in
October  1987 identified  several  Superfund  problem  areas  related  to  human
resource management:    staffing and  skill  shortages,  employee turnover,  pay
differentials, and  Superfund  training.

     OERR and OPMT,  with  the  assistance  of the  Office of  Human  Resources
Management  (OHRM)  and  the Regions, have  taken significant steps  in  FY88  to
address these Superfund  issues.   They have designed the OSC/RPM Support program
to improve the ability of OSCs  and RPMs to perform  their jobs  efficiently  and
effectively,  and to  provide OSCs, RPMs,  and  others  involved  in  hazardous
materials cleanup with  opportunities to grow professionally.
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12.0 HEALTH-RELATED RESEARCH AND DEVELOPMENT

     12.1 Overview

     CERCLA authorizes significant new health-related research programs in both
EPA and the Department of Health and Human Services (HHS).  Although the amended
statute does not clearly differentiate among research areas and agencies in the
health  research  area,  a broad  research  agreement was reached between  the two
agencies in FY87  on  the  scope of each research program.  The  EPA  program will
focus on the development and evaluation of toxicological test methods,  exposure
assessment methodology,  and risk  assessment and characterization techniques.
The Agency for  Toxic Substances  and Disease  Registry  (ATSDR)  will  conduct
research related  to  its  health assessment responsibilities under  CERCLA.   The
National  Institute  of  Environmental Health  Sciences  (NIEHS)  will  support
multidisciplinary biomedical  research through  grants  to  universities.

     12.2 EPA Health-Related Research Program

     The  overall objective  of  EPA's health-related  research program is  to
improve  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.   Research
conducted  under  this  program  commenced  in  previous  years and  continued
throughout FY88.

     12.2.1  Health Effects, Risk Assessment, and Detection Research

     The  health-related  research program  has   several  components  that  are
organized conceptually  in a matrix.    Three  of these components correspond to
OERR's  three steps in the public health  evaluation process.   They  are:

     •    Toxicity Assessment.   Key  toxicity data will  be  developed
          for use in risk assessment,  these  include:   rapid response
          toxicity testing and field screening of  priority compounds;
          evaluation  of  the   toxicity  of  incinerator and  other
          treatment residues; evaluation of  PCB carcinogenicity; and
          human reproductive risks from  chemical  mixtures.   In FY88,
          research continued on a  rapid  response  bioassay battery  to
          determine  the  developmental  toxicity,  neurotoxicity, and
          general toxicity  of site samples.   Also, genetic  activity
          profiles  were  prepared  on  the first  50  most  hazardous
          substances found at Superfund sites.  These profiles support
          the Toxicological Profile Development Process.

     •    Exposure Assessment.  To  improve the confidence and accuracy
          of human exposure estimates  at CERCLA sites,  this  research
          and  development will  characterize parameters needed for
          exposure assessment,  validate  existing  models,  and develop
          approaches for assessing multimedia exposure and integrating
          exposure assessments.
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     •    Risk Characterization.  Methods  for  characterizing health
          risks and environmental effects  of chemical  mixtures  will
          be developed and assistance will be  provided to Superfund
          site risk assessment.

     The other components of the Agency's research program 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 research will predict the
               bioavailability of chemicals more  accurately in
               the following ways:  defining rates of inhalation,
               and  skin  and  oral  absorption;  characterizing
               pharmacokinetic    parameters    of    uptake,
               distribution,     and    metabolism;    developing
               physiologically based pharmacokinetic  models for
               multiple  routes of  exposure  and  for  multiple
               compounds;    and    identifying    sensitive
               subpopulations.

          2.   Biomarkers  of   Exposure   and  Effect.      This
               initiative  will  focus  on  better  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.  In FY88,
               the structure  of the baboon lung was compared to
               that  of  a  human.   This  work  will  assist  in
               modelling uptake  and distribution of hazardous
               substances in the human lung.

     •    Chemical  Mixtures.    Focus of  the  research  will  be  on
          developing  toxicological  models  to  predict  interactions,
          identification of  classes  of contaminants  that  may yield
          additive,  synergistic,  or  antagonistic  responses,   and
          statistical  methods  for  analyzing high-dimensional  data
          sets.  In FY88, research continued  on efforts to establish
          dose-response relationships and on the elucidating mechanism
          of interactive effects  with chemical mixtures.  The initial
          focus of this research was on acute liver injury.

     •    Noncancer  Health Effects.    Reproductive  toxicity  is  a
          critical  endpoint  of  interest  for OERR and will be  the
          initial  focus  of  this  research.   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

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          endpoints.    In  FY88,  various  In  vitro  systems  were
          investigated  for  their  utility  in  screening  hazardous
          substances  for  neurotoxicity.   The study  concluded that
          these methods are  not yet  sufficiently advanced for this
          use.

     The research  projects described above  are  two to  five  years in length;
however, progress reports  will be prepared or program reviews  will  be  conducted
annually.

     1222 Toxics Integration Branch

     In FY87,  the  Toxics  Integration Branch  (TIB)  was created within OERR  to
focus OERR's health and risk  assessment activities within one branch.  TIB  is
the point of contact at EPA for ATSDR.   TIB is responsible  for determining OERR
health research needs, developing policy and  guidance  documents for conducting
health assessments and risk assessments at Superfund sites,   and for  providing
training and assistance to Regional offices on health  and  risk assessments.

     For example, TIB is responsible for the  following specific activities and
projects:

          •    Revising and updating the Superfund Public Health
               Evaluation   Manual    (SPHEM)   and  developing
               associated training;

          •    Ensuring increased  efficiency and  automation  of
               risk assessment procedures;

          •    Providing technical information and assistance  to
               Regional  offices, •  including Agency  data   on
               chemicals,   and information  on health  and risk
               assessment  documents  and  of risk assessment
               reviews;

          •    Ensuring that  OSWER policies on risk assessment
               are  internally  consistent  and   follow  Agency
               policy;

          •    Determining  and  tracking  OERR health research
               funding needs; and

          •    Coordinating OERR interaction  with  ATSDR.

     In  FY88,  TIB worked  to  develop  better "tools"  for the  performance  of
Regional site  risk assessments,  improved  policy  guidance for conducting and
reviewing risk assessments, and  placed  an increased emphasis on user needs  in
the  Superfund  health-related research  program.    TIB  and  the Health Sciences
Section of OWPE jointly established a formal  quality assurance program that  is
intended to provide technical assistance on the  most  difficult Regional risk-
related  issues and to  identify  inconsistencies   in methods  and  assumptions.
Under  this  program,   each  Region was requested  to  submit two representative
Superfund risk assessments each year for Headquarters review.   In addition, TIB

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instituted an electronic mail box to receive questions from the Regions on risk
assessment  and  is  currently  using the  OSWER electronic bulletin  board to
disseminate chemical-specific risk  information to the  Regions.

     The primary source of Superfund risk assessment guidance  is  the  SPHEM.  In
FY88,  TIB  established  a broad-based workgroup  to  revise this  manual.   The
workgroup identified major concerns and issues through interviews with Regional
and  Headquarters  program  staff,   state  risk  assessors,   federal   facilities
personnel, ATSDR, and contractor staff.  The  first  draft of the revised manual
is currently being prepared and is  expected to be completed in 1989.  A final
version of  the revised manual  should  be published  sometime  in  the  summer of
1989.

     TIB also completed and is  distributing the final  version of the  Superfund
Exposure Assessment Manual.   This document provides detailed guidance on the use
of exposure assessment  models  and  information on the public health  evaluation
process.  In addition,  in FY88, TIB distributed to the Regions and  states two
completed revisions  to the  Public  Health Risk Evaluation Data  Base  (PHRED).
This PC-based tool updates the  information found in the appendices to  the SPHEM.

     123 The Agency for Toxic Substances and Disease Registry

     CERCLA mandates   that  ATSDR  perform  specific public health   activities
associated with  actual or potential exposure  to toxic  substances identified at
hazardous waste  sites.    The ATSDR research  program focuses  on  assessing the
relationship between exposure to toxic substances and the resulting human health
effects, and also on effective  ways to  inform the public of health risks.

     Section 104(i)(6) of CERCLA requires that ATSDR perform a  health  assessment
for each facility listed on the NPL.  By December  10, 1988, ATSDR must complete
these health assessments  for all facilities listed or proposed for  listing on
the NPL by October 17, 1986.  For facilities proposed for  listing after October
17, 1986, ATSDR must complete health assessments within one year  of  the date of
proposal for inclusion on the NPL.  This section  directs ATSDR to consider NPL
schedules and EPA's schedules for conducting RI/FSs when establishing  priorities
for health assessments.

     A health  assessment is the evaluation  of data and information  about the
release of  toxic substances into the environment.   It assesses any  current or
future  impact  on public health, develops  health  advisories  or  other health
recommendations,  and  identifies  studies or actions  needed  to  evaluate and
mitigate  or  prevent  human health effects.   In   FY88,  ATSDR  entered  into
cooperative agreements  with 16 states  to perform health  assessments at sites
located in these states.  ATSDR also conducted training sessions on  conducting
health assessments for personnel from these  states.   TIB  staff participated in
these training sessions to ensure that state personnel understood the Superfund
process and their role  in it.

     ATSDR  also  issued preliminary guidance  on conducting health assessments
during the fiscal year.   This preliminary guidance contains a uniform format for
the presentation of health assessments and closely follows  the  SPHEM,  using  most
of the same reference sources.   TIB  and  the Office of Waste Programs Enforcement
(OWPE) have provided ATSDR  with comments on the health assessment guidance.

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     In addition, EPA and ATSDR have agreed to a process for EPA review of draft
ATSDR health  assessments.  This  agreement  calls for  the  signature of  Branch
Chief (or equivalent, depending upon the EPA Region)  on all EPA comments  on the
final draft of  a health assessment.   These  comments  will  be submitted  to  the
Associate Director of ATSDR's Health Assessment Office.  If  issues  that  cannot
be resolved  at   this  level  arise over  a specific health  assessment,  the  EPA
Regional Branch chief may ask ATSDR not to finalize the health assessment until
a discussion  of the issues can take  place  at a  higher level.   The agreement
provides for extensive communication at  the staff and mid-management level, with
higher-level  involvement  required only  in extremely controversial cases.

     Section 104(i)(2) of CERCLA requires EPA and ATSDR to develop a list  of 100
hazardous substances  commonly found at  NPL  sites that pose  significant  human
health risks.   The  deadline for preparing this  list  was April 17,  1987.   This
section also requires these two agencies to  revise the original list by October
17, 1988, and to add another  100 hazardous substances  to the  list.

     Section 104(i)(3) requires ATSDR to perform toxicological profiles of each
of the listed substances.   These toxicological profiles must  be  completed at  a
rate of 25 per  year  for the first 100 substances.  Profiles  of  the second 100
substances on the list must  be completed within three years  after their  addition
to the list.  A toxicological  profile  of a  substance involves an  analysis of
available toxicological and epidemiological data  to  determine health effects
from exposure to the substance.  The profile will determine  if there  is  adequate
data to  set  levels of  exposure that  cause  health risks,  and if not,  it  will
identify toxicological  tests  necessary  to determine that level.

     ATSDR  and   EPA  compiled  a  list  of the  first  100   priority hazardous
substances and  published  a  Federal Register notice (April 17, 1987) proposing
guidelines for developing the first 25 toxicological profiles.  In FY88, EPA and
ATSDR  revised  the  list  to  include   an  additional  100   priority hazardous
substances.   These  substances were  added   to  the list  using  data  from  the
Contract  Laboratory Program  (CLP),  NPL listings,  and  reportable quantities
information.

     Also in FY88, ATSDR completed toxicological profiles of 14 of the  first 25
substances on the priority  list.   The remaining 11 profiles  have been through
public comment  and are  currently being  finalized.  ATSDR drafted toxicological
profiles of  the second group of  25  substances  and sent them to EPA  Regional
offices for review in December  1988.

     EPA and  ATSDR  established  a mid-level  management "steering committee" in
FY88.  This  committee meets  four times each year  to discuss  interagency  progress
concerns and  to resolve site-related  problems  that could affect ATSDR and EPA
personnel.  This  committee  functions  at the  Branch Chief and staff level.  An
ATSDR representative and an EPA Regional representative serve on the committee.
At the end of each year,  EPA  will appoint a  new Regional committee  member.

     12.4 The National Institute of Environmental Health Sciences

     Section 311(a) of CERCLA authorizes a research program at NIEHS to develop
advanced techniques for detection and evaluation of the effects on human  health

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of hazardous  substances.   This section also  authorizes  research on methods  to
assess the risks to human health presented by hazardous substances, on methods
and technologies to detect hazardous substances in the environment,  and on basic
biological, chemical, and physical methods  to reduce  the amount and toxicity of
hazardous substances.
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13.0 EXECUTIVE BRANCH ACTIONS TO IMPLEMENT CERCLA

     13.1  The National Response System

     The  National Contingency  Plan  (NCP)  was developed to  ensure that  the
resources and expertise of the federal government would be immediately available
for those relatively rare but  very serious oil and hazardous substance incidents
that require a national  or regional response.   The NCP  established a hierarchy
of mechanisms  that  together form the  National Response System.   The hierarchy
consists of:

     •    The National Response  Team  (NRT);

     •    The Regional Response  Teams  (RRTs);

     •    The On-Scene Coordinators (OSCs); and

     •    The National Response  Center  (NRC).

     13.1.1 The National Response Center

     The NRC  acts as  the national  communication center,  receiving reports  and
notifying the  OSCs  of  incidents.  If  a release of oil  or hazardous substances
occurs that  is greater  than the legally specified quantity  for  the substance,
the party responsible for the  incident is required by law to notify the National
Response  Center   (NRC).   Between  October  1987 and  September  1988,  the  NRC
received more than 16,000 notifications.  The Center is funded by the Department
of Transportation and  EPA,  and  is staffed  by  Coast  Guard officers  and  Marine
Science technicians.  The staff is  trained to  collect specific information from
the people  reporting  incidents.  The  types of incidents reported include  oil
spills, derailed tank cars or overturned trucks leaking toxic gases, and fires
and  explosions  that  release  hazardous  substances.     Designated  hazardous
substances were involved in 21 percent of the FY88 reports, oil and oil products
in  49  percent,   and  other  hazardous  materials  (such  as  natural  gas  and
explosives) were involved in  30  percent.

     When  the reported  incident  involves  an  oil  spill or  a  release of  a
hazardous substance, the Center notifies a predesignated On-Scene Coordinator
(OSC)  assigned to the  area  of  the  incident.   The  Center  uses  a  variety  of
computer systems to locate information to assist the  OSC.   For example,  the  Oil
and Hazardous  Materials Technical Assistance  Data  Systems  (OHMTADS) and  the
Chemical  Hazard   Response Information  System  (CHRIS)  are  used  to  identify
chemicals when only partial  information is available.   Other systems help  to
predict the  likely  direction  of a spill's  movement.   A marine  transportation
data  base provides  access to  historical  information on  vessels,  hazardous
cargos, and parties who  may be  involved.

     13.12 Regional Response Teams

     The RRTs  work  with state governments  to  provide guidance and assistance
within their regions.   They ensure  that,  in an emergency, appropriate  federal
assistance will reach the scene quickly following  an  OSC request.   During FY88,
RRTs were activated for  40 incidents.   These ranged from the January  2,  1988,


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Ashland oil spill into the Monogahela River  to telephone notifications alerting
RRT members that their assistance might be needed.  In addition to the Ashland
spill, the RRTs participated in responses to a 212,000 gallon oil spill in the
Chesapeake Bay, a 990,000 gallon spill of carbon black feed stock oil into the
Mississippi River, a pesticide fire in  North Dakota, a 365,400 gallon oil spill
in San Francisco Bay, and a 600,000 gallon oil spill  in the Gulf of Alaska.

     RRTs also conducted  eight major simulation  exercises of regional and OSC
contingency plans to test  federal response capabilities and to ensure that state
and local  response  plans  are compatible with  the federal plans.   One of the
simulation exercises  was  conducted jointly with Canada.   In addition,  a team
from the USSR observed a specially designed exercise in Alaska that lead to the
development of a US/USSR  joint  contingency plan.    In addition,  RRT members
assisted  and  participated in  exercises  conducted  by  states  and  observed
exercises carried out by other groups.

     There are 13 standing Regional Response Teams (RRTs), one for each of the
ten federal Regions plus  one  each  for  the  Caribbean,  Oceania (Pacific Basin),
and Alaska.    RRT  members include  representatives from  a number  of federal
agencies and from each state within the Region.

     The RRT  provides  a  scheduled  forum  within  which  federal  agency field
offices and  states  exchange  information  on their capabilities  for response.
During an  incident,  an RRT may  be activated on-scene, or through conference
calls.  As  necessary, RRT representatives  from  member agencies who  have the
technical expertise or contacts needed by the OSC  establish an incident-specific
RRT to provide technical advice or resources required at the scene of a release.

     Each RRT  has developed  a regional contingency plan  to  ensure  that in an
actual incident,  the  response roles and responsibilities  of the agencies and
states are clear.  The plan describes how all levels of government will respond
and interact effectively  if called  upon in  an  emergency.   The RRT reviews the
reports of the OSCs to identify problems in the  response capabilities of the
Region, to revise the  plan as needed,  and  to work with states.   The RRTs also
work with OSCs on OSC contingency plans for  specific areas  in EPA Regions.  The
simulation exercises described above test the regional  and  OSC contingency plans
to ensure their effectiveness.

     13.13 The National Response Team

     The  National  Response   Team  (NRT)   is  a  body of  14  federal  agency
representatives  with  expertise  related   to handling incidents.    The  NRT
coordinates the  activities of its  14 member agencies  from the national to the
regional level to ensure  a unified federal  approach  on policy questions about
national oil  and hazardous substances  response  preparedness.   Exhibit 13.1-1
lists the 14  federal  agencies that have representatives  in  the  NRT.   A major
influence on the NRT's FY88 activities were the requirements included in SARA.
For example,  the NRT  helped  EPA draft a  revised Subpart B of the  NCP that
defines the organizational structure and responsibilities of the NRT, RRTs, OSCs
and the NRG.  The NRT also provided comments and review for EPA's revisions to
other parts of the NCP.  In addition, the NRT
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       Progress Toward Implementing Superfund:  Fiscal Year 1988
                        Exhibit 13.1-1
          National  Response  Team Members
      Environmental Protection Agency

      United States Coast Guard

      Departments of Commerce

      Department of the  Interior

      Department of Agriculture

      Department of Defense

      Department of State

      Department of Justice

      Department of the  Treasury

      Department of Health and Human Services

      Department of Energy

      Department of Labor

      Federal Emergency  Management Agency

      Nuclear Regulatory Commission

      SOURCE:  National Response Team. Annual Report to  Congress.
             1988, March 1989.
Began a  review of member  agencies'  technical guidance on
hazards analysis to develop a coordinated  federal guidance
document on the subject;

Reviewed  Mexican  and  Canadian  joint  contingency plans
developed through  negotiations  between EPA and Mexico and
the Coast Guard and Canada;

Reviewed  the  development  of  a  US/USSR joint contingency
plan;

Developed  Criteria  for  Review of   Hazardous  Materials
Emergency Plans (NRT-lA) to help RRTs  review selected local
emergency response plans required by  SARA  Title III;
                            185

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     •    Appointed a computer applications committee  that  drafted a
          directory of  federal information resources  for  emergency
          planning and response;

     •    Coordinated  federal emergency  preparedness  and  response
          training activities; and

     •    Continued to work to increase staffing  support  for RRTs.

     The NRT  does  not respond directly to  incidents,  but  provides  assistance
when requested during an incident.  The NRT was not requested  to assist in the
response to any  incident  during  FY88.  The major areas of  NRT activities are
preparedness,   training,  international coordination, support of the RRTs,  and
management of  the National Response  System.   The work of the  NRT  extends  over
longer periods of  time than does the work  of the more response-oriented  NRC,
OSCs, and RRTs.  The NRT is primarily a planning  and coordinating  body.

     13.2 Federal Facilities Program

     Section  120 of  CERCLA indicates that  all provisions,  guidelines,  rules,
regulations, and criteria contained in CERCLA apply to facilities  owned and/or
operated by  the  federal government.   To  focus  attention on these  federal
facilities, and  to  implement the  CERCLA  requirements  concerning them,  EPA
established the Federal Facilities  Compliance Task Force in OWPE  in 1987.   In
fiscal 1988,  the  Federal  Facilities Compliance  Task  Force became  a permanent
office within OWPE, and is now known as the Federal Facilities Hazardous Waste
Compliance Office.

     The Federal Facilities  Hazardous Waste  Compliance Office works with EPA
Headquarters,   the  Regional offices,  and  states  to  resolve issues  concerning
federal  facilities.    The  goal of  this office  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.   The  Federal  Facilities  Office focuses  on the
management of  the  federal  agency docket,  policy and guidance  development, and
compliance monitoring.

     132.1  Federal Agency Hazardous Waste Compliance  Docket

     CERCLA section 120(c) requires EPA to establish a Federal  Agency 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.
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     The initial federal agency docket was published in the Federal Register on
February 12, 1988, and listed 1,095 federal facilities.  Of the total number of
facilities  on  the docket,  the Department  of Defense owns and/or  operates 594
facilities  (54.25 percent) and the Department  of  Interior owns and/or operates
254 facilities (23.20 percent).

     EPA is required to update the federal agency docket every six months.  The
first update to the docket  was published in the Federal Register on November 16,
1988.   (A  notice providing  editorial  corrections to  the  first update  was
published  in the  Federal  Register  on  December  7,  1988.)   The  first  update
contained  technical  corrections  to  the  initial  docket listing,  including the
deletion and addition of facilities  to  the initial  docket.

     The first update  to  the  federal agency docket  also  included the addition
of  105  new  federal  facilities.    Exhibits  13.2-1   and  13.2-2 illustrate  the
numbers of  new federal facilities added  to  the  docket through this  update by
federal department and  agency  and by EPA Region, respectively.   This addition
of new federal facilities brings  the total number of facilities that appears on
the docket  to 1,170.

     The  Federal Agency Hazardous Waste  Compliance Docket  is available  for
public inspection.   In order  to furnish  information  to the  public  regarding
facilities  contained in the docket, EPA established information repositories in
all  10  of  the   EPA Regional   offices.    Information  submitted  by  federal
departments and agencies to EPA concerning facilities is included in the docket,
and is organized and indexed  according to a uniform system.   This information
is submitted by federal departments and agencies pursuant to CERCLA section 103
and under the permitting and activity notification  provisions of  RCRA sections
3005, 3010, and  3016.

     13.2.2  Federal Facility Preliminary Assessments/Site Inspections

     Executive Order No. 12580 delegates  the responsibility for conducting PAs
and Sis at  federal facilities to the federal departments  and agencies that own
and/or operate  those facilities.   EPA has  the  responsibility to  ensure that
these  activities  are  performed  and   that  guidance  and  organized  training
workshops on conducting PA/SIs are provided for  other federal departments and
agencies.

     The statutory deadline for  the performance  of  PAs by  federal departments
and agencies at facilities  listed on the initial federal agency docket was April
17,  1988.   If a PA indicates that  additional evaluation  of the  facility is
necessary,  the responsible federal department or agency must  conduct an SI to
provide  EPA with all  of  the  information  necessary  to  perform  a  full  HRS
evaluation of the site.  EPA will then propose the facility for inclusion on the
NPL if it meets the established HRS scoring threshold.   EPA has determined that
PAs were not submitted  for 108 federal  facilities by the  statutory deadline.

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

     On July 22,  1987,  EPA added  32 federal facility sites to the NPL,  the first
federal facilities to be included on the list as final  sites.  The fifth update
to the final NPL  is  scheduled to be  published  in  1989.   It is expected that a

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         Progress Toward Implementing Superfund: Fiscal Year 1988
                         Exhibit 132-1
Federal Facilities Added to the Federal Agency Hazardous
      Waste Compliance Docket by the First Update
Department or Agency
Defense
Air Force
Army
U.S. Army Corps of Engineers
Navy
Other Defense Agencies
Interior (including Bureau of
Land Management)
Agriculture
Energy
Transportation
National Aeronautics and Space
Administration
Treasury
Small Business Administration
Tennessee Valley Authority
Total
NOTES : ^-The number of facilities may vary in
change a facility's status.
^Percentages may not total 100 because
SOURCE: 53 FR 46364. November 16. 1988.

Number of
Facilities1
42
16
16
4
5
1
23
22
10
3
2
1
1
1
105
subsequent listings
of rounding.
Approximate
Percent off Total2
40.00


21.90
20.95
9.52
2.86
1.90
0.95
0.95
0,95
100 .. 00
because further information may

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                  Exhibit 132-2
       Distribution by  Region of Federal  Facilities Added to the
         Federal Agency Hazardous Waste  Compliance  Docket
                            by the First Update
Region
1
2
3
4
5
6
7
8
9
10
Total
NOTES :
SOURCE :
Number of
Facilities
2
5
6
4
7
31
9
12
14
15
105
•'•The number of facilities
listings because further
facility's status.
Approximate
Percent of Total2
1.90
4.76
5.71
3.81
6.67
29.52
8.57
11.43
13.33
14.29
100.00
may vary in subsequent
information may change a
Percentages may not total 100.00 because of
rounding .
53 FR 46364. November 16. 1988.


number of  federal  facility  sites  will  be added to the final NPL  through this
update.  In addition,  one  of the non-Federal facility sites that was  previously
listed on  the NPL  is  expected to  be classified as a federal facility in this
update.

     There are currently 30 additional federal facilities that have been proposed
for the NPL.  Fourteen of these federal  facility sites were proposed for the NPL
in fiscal 1988;  the other sites were proposed prior  to FY88.  EPA also published
a proposal to the NPL specifically for  federal facility sites in July 1989.

     132.4  Federal Real Property Transfer Regulations

     CERCLA section 120(h)(l)  requires that anytime the U.S. government sells
real property on 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 U.S.  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 any
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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


remedial action found to be necessary after the property  is transferred will be
conducted by the United States.

     Section 120  also  requires EPA to  promulgate regulations on the  form and
manner of the notice to be put in sales contracts and deeds.  Regulations were
proposed by  the Agency 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;  the time of
storage, disposal, or release; and the quantity stored, disposed of,  or released.
The Agency  also proposed  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 1000 kilograms of hazardous substances
were stored would also be exempt.

     The final  rule,  with minor changes  from  the proposal  is  expected to be
published in the Federal Register during 1990.

     13.2.5 Federal Facility Agreements Under CERCLA Section 120

     A  Federal  Facility  Agreement  (FFA)  is  a  comprehensive  document  that
addresses hazardous waste activities at a  federal facility; it may  include some
or  all  phases  of  activity from the  RI/FS through  the  implementation of the
remedial action.   FFAs formalize  the procedure  and  timing  for  submittal and
review of documents  and establish  a  mechanism  to resolve disputes.  FFAs must
comply with the public participation requirements of CERCLA section 117 and are
enforceable by citizens and states through citizens suits. Additionally, CERCLA
authorizes assessment of civil penalties by states and citizens against federal
departments and  agencies  for failure  to  comply  with FFAs.   EPA is currently
working with  states  and  federal  departments  and  agencies   to  negotiate and
implement three-party FFAs for federal  facilities listed on the NPL.

     EPA Headquarters and the Departments  of Defense and  Energy agreed  to model
language for key provisions of a  number  of CERCLA  FFAs in  fiscal 1988.   The
model language deals with  policy  issues that required resolution before site-
specific agreements  could  be finalized.   The model provision topics  include:
title,  jurisdiction,  purpose,  statutory  compliance/RCRA-CERCLA  integration,
consultation  with  EPA,  resolution  of  disputes,   enforceability,  stipulated
penalties,  extensions,  force majeure, and funding.    The EPA Regional offices
will negotiate  the site-specific provisions of agreements,  notably those  sections
dealing with the actual work that needs to be performed and the schedules to be
met.

     The Agency has entered into four CERCLA FFAs  with  other federal departments
and agencies.   In November 1988, EPA and DOE reached an  agreement  in which DOE
agreed to investigate  and  clean up contaminated  ground  water at its  Lawrence
Livermore National Laboratory in Livermore, California.   In December 1988, EPA,
DOE,  and  the  State  of Utah signed  an agreement whereby  DOE will  clean up
contamination  at its Monticello,  Utah facility, which  was  built  in  1942 to
produce vanadium.   Also in  December  1988,  EPA  and  DOD  signed two FFAs.   The
first agreement requires DOD  to investigate and clean up Tucker Air Force Base
in Oklahoma City, Oklahoma.   The second EPA/DOD agreement requires the Army to
conduct investigative and remedial activities at  the Sacramento Army Ammunition

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


Depot in Sacramento,  California.   The Agency  is currently negotiating agreements
for the cleanup of waste  sites at more  than  20 other federal facilities around
the country.

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

     Section 120(e)(5)  of CERCLA  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 concerning  the  following areas:    progress  in reaching interagency
agreements (lAGs); 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.

     EPA  has 14 facilities  subject  to  CERCLA  section 102(e)(5)  reporting
requirements.  This  number  differs  slightly from  the number of EPA facilities
listed on  the initial  Federal Agency Hazardous  Waste Compliance Docket due to
changes  in facility  status that  occurred after the  original Federal Register
notice was published.  The first update  to the federal agency docket did not add
any EPA  facilities to  the docket.  The 14 EPA facilities listed in the docket
are identified in Exhibit 13.2-3.

     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.
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           Progress Toward Implementing Superfund:  Fiscal Year 1988
                            Exhibit 13.2-3
      EPA Facilities on the Federal Agency Hazardous
      	Waste Compliance  Docket	
                Facility/Location                        Region
      1.    Narragansett Environmental  Research         1
           Laboratory,  Narragansett, RI

      2.    Environmental Services  Division             2
           Laboratory,  Edison,  NJ

      3.    Environmental Photographic                   3
           Interpretation Center,  Warrenton,  VA

      4.    Environmental Services  Division             3
           Laboratory,  Annapolis,  MD

      5.    Environmental Research  Facility             4
           Gulf Breeze, FL

      6.    Andrew W.  Breidenbach Environmental         5
           Research Center,  Cincinnati,  OH

      7.    Center Hill  Hazardous Waste Engineering     5
           Research Laboratory,  Cincinnati,  OH

      8.    Environmental Services  Division             5
           Laboratory,  Chicago,  IL

      9.    Testing and  Evaluation  Facility,             5
           Cincinnati,  OH

      10.   Combustion Research Facility,               6
           Jefferson, AR

      11.   Environmental Services  Division             7
           Laboratory,  Kansas City,  KS

      12.   EPA Mobile Incinerator                       7
           McDowell,  KS

      13.   National Enforcement Investigation          8
           Center, Denver, CO

      14.   Environmental Services  Division            10
           Laboratory,  Manchester, WA

SOURCE: 53 FR 4280, February 12, 1988.
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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


14.0  EXECUTIVE BRANCH ESTIMATE OF RESOURCES NEEDED TO COMPLETE
     SUPERFUND IMPLEMENTATION

     14.1 Introduction

     Section 301(h)(l)(G) of CERCLA 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.  This chapter
includes complete  information through FY90.    This  material  is  presented in
sections 14.1, 14.2,  and 14.4  of this chapter.   The resource estimates presented
in these sections  are  divided between those needed  by EPA and those needed by
other federal  departments and agencies.   Data on resources beyond fiscal 1990
are in the early stages  of  development, as part of the  fiscal  1991 budget.  An
estimate of the  long-term costs  of cleaning up  the  existing NPL is included,
however, in section  14.3, together with an overview of the  estimating method
being used.

     Congress  provided  EPA with  $3,964,000,000  in  budget  authority  for the
implementation of CERCLA, as amended,  for the  three-year period of FY87 through
FY89.  The actual  level of  funds  obligated annually may be slightly less than
the  level  of  budget  authority provided.    The budget  authority  funds  are as
follows:

                          1987          $1,411,000,000
                          1988          $1,128,000,000
                         1989          $1.425.000.000
                         TOTAL         $3,964,000,000
     The  resources  estimate  in  this  chapter  is  based  primarily  on  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 the other
federal departments and agencies.  Estimates include  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, activities that
are underway, or  are  actually in a planning  stage.   The estimate of resource
needs beyond FY90 relies on many of the same cast factors and assumptions, but
includes all of the activities that would be necessary to complete cleanups at
the remaining inactive NPL sites.

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

     •    EPA Superfund budgets and budget estimates for FY88, FY89,
          and FY90,  including  budget  requests from  other  federal
          departments and agencies;

     •    Data  submitted to  EPA by  other federal  departments  and
          agencies under an approved General Services Administration


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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


          (GSA) Interagency Report Control Number  (IRCN)*, issued on
          February 5,  1988,  as  required under  the provisions of 41
          CFR 201-45.6;

     •    The federal facilities docket developed under section 120(c)
          of  CERCLA  and  each individual  federal  department's  and
          agency's Annual  Report  to Congress  on Federal Facilities
          Implementation,  as required  under  section  120(a)(5)  of
          CERCLA;

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

     •    EPA's Annual Report to the Office of Management and Budget
          on  Pollution  Abatement  Needs  at  Federal   Installations,
          required under  Executive  Order 12088  and based on annual
          pollution  abatement  plans   (A-106  reports)  by   federal
          departments and agencies;  and

     •    Various EPA information systems,  primarily the Financial
          Management System  (FMS).

     These sources will also be used for future Reports, but  at the same  time,
the Agency  is working  to identify data  requirements,  improve  data  quality,
develop   cost  estimating   methods,   and   collect   additional  information.
Specifically,  EPA has completed a  resources estimate for the  balance of  the
current authorization, in  the outyears  of  1990 and 1991, and for the  unfunded
period  beyond 1991.   This  long-term  effort  has  been coordinated  with  the
development  of the  1991 budget.    In  conjunction with  the proposal of  the
National  Contingency Plan and  its  policies  affecting  program  direction  and
scope,  EPA  is moving closer to a more  complete implementation cost estimate.
The initial results  of this effort  are  presented  in  section  14.3  of  this
chapter.

     EPA's  ability  to project  the  federal  resources  requirement  for CERCLA
implementation will  improve with the publication  of the final  NCP   and  more
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.

     142 EPA Estimate of Resources Necessary to Complete Superfund Implementation

     In  estimating   the   resource  requirements  for  EPA  to  complete   the
implementation of CERCLA,  the Agency  typically focuses its projections on the
expected costs of the remedial and removal  programs in future years.  These two
programs are  the major components of the Superfund program and account for the
       Collection of other Federal department and agency resource requirement
data is approved under GSA IRCN 0354 EPA  -- Annual.

                                      194

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


majority of Superfund expenditures by the Agency.  The estimates of the  resource
needs for these two program areas  are projected for FY89 and  FY90.

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

     •    Changes in Superfund program policies and procedures  because
          of  the  revised NCP,  particularly the cleanup standards  as
          required under  section  121  of CERCLA;

     •    Changes in the remedial program because  of revisions to  the
          Hazard  Ranking System,  as  required under  section  105  of
          CERCLA;

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

     •    The  effects  of  the  long  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  areas:
direct site support,  program support, and site-related support.  The proportion
of Trust Fund resources  allocated to  each  of  these program  areas  may vary over
time.  Variations may be brought  about by  concentration of  activity in certain
program areas, changes in the focus of program implementation, and the  maturity
of the Superfund  program.   Other federal department and agency activities  are
also supported by resources from  the  Trust Fund.

     Direct Site Support

     Direct  site  support  accounts   for   approximately  74  percent of total
Superfund resources and funds:

     •    Direct Site Work  (57 percent), which consists of:

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

     •    Site Support  (17 percent),  which consists of:

          Extended remedial actions,

                                      195

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


          Community relations,
          Contract laboratory support,
          Contract management,
          Enforcement,
          PRP settlements, and
          The Superfund Innovative Technology  Evaluation program.

     Program Support

     Program support  accounts  for approximately 20 percent of  total  Superfund
resources and supports:

     •    Siting capacity and community  assistance  grants,  training,
          the Office of the Inspector General, and other miscellaneous
          activities  (6 percent);

     •    Research  and support  for  other  federal  departments  and
          agencies (6 percent);

     •    Information  management and  policy/planning  activities  (3
          percent); and

     •    General and financial  administration (5 percent).

     Site-Related Work

     Site-Related  Support  accounts  for  approximately  6  percent  of  total
Superfund resources and supports:

     •    Preliminary enforcement and  cost recovery activities  under
          section 107 of CERCLA  (0.5 percent);

     •    National Response Team and Regional Response Team activities
          (0.8 percent); and

     •    Health  studies  and  research, criminal casework,  and  other
          miscellaneous activities (4  percent).

     PRPs contribute  to the hazardous substance cleanup  effort by undertaking
and financing voluntary or  enforced remedial activities,  thereby  reducing the
number  of  remedial   actions  that  require  Superfund  expenditures.    EPA  is
currently  developing  and  implementing  policies   designed  to  encourage  PRP
cleanups.

     142.1  Remedial Program Costs

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

     •    The projected size of  the NPL;
                                      196

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


     •    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 PRPs.

     Exhibit 14.2-1 presents summary data on the actual and planned elements of
EPA's  Superfund actions.    Exhibits  14.2-2  and  14.2-3   present  data  on EPA
Superfund resource estimates in dollars  and workyears,  respectively.

     1422  Cost Recovery Revenues

     In addition to the direct remedial and removal actions 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,  there  is  a   three-year delay  between
expenditures from  the  Trust  Fund for final  site work and the  reimbursement of
these response costs by PRPs to EPA.

     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
expenditures  from  the Trust 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  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 will  directly
undertake  actual  cleanups.   As a result,  more  Fund-financed  actions  will be
taken at sites where there is less likelihood of cost recovery because there are
fewer PRPs connected with these sites.   The cost recovery rate for these sites
may be lower than  the rate for  the earlier sites.

     1423  Direct Clean-up Actions by Potentially Responsible Parties

     Although  the  cost recovery  revenues obtained  from  PRPs  will  reduce the
costs  of the  removal  and  remedial  programs,   the  available  data  for these
revenues are not sufficient to allow for an accurate e'stimate of the percentage
of Fund-financed removal  costs and remedial costs that will be recovered  from
PRPs.  The Agency is putting  significant  effort  into  improving  its cost recovery
performance, as is demonstrated by the FY87 and FY88 cost recovery amounts, the
highest in the program's history.

     143 Estimation of Resource Needs, Beyond Fiscal 1990, to Complete the
         Cleanup of the Existing National Priorities List

     EPA  has  developed  a tool  to estimate  the  long-term  resource  needs of
Superfund.   The estimating  approach  provides meaningful  long-range forecasts
and  is  flexible enough to  accommodate  a  wide  range of  possible  programmatic
conditions.  The estimating  approach uses  a computer-based model which


                                      197

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                 Exhibit 142-1
              Summary of EPA  Superfund Actual/Planned
                         Actions by Fiscal Year1

Activity
Removal Action Starts2
Pre-Remedial Actions
PA Completions
SI Completions
NPL Additions3
Remedial Actions4
RI/FS Starts
ROD Completions
RD Starts
RA Starts
Final RA Completions
NPL Deletions6
1987
Actual
304

4,001
1,343
99

183
75
94
54
5 8
0
1988
Actual
328

2,884
1,237
229

150
152
99
72
7
5
NOTES: * The data shown are for Trust Fund-financed actions and
NPL facilities/sites,
are not cumulative .
except for removal
1989
Planned
190

2,500
1,325
75

74
160
168
119
15
8
1990
Planned
190

2,500
1,325
75

80
160
195
130
35
15
those undertaken by PRPs at
actions. The numbers shown are
by year and
2 NPL and non-NPL sites.
3 NPL facilities/sites
proposed for final
Data are for both first and subsequent
listing on the
starts by Fund-
^ Data represent completion of all construction work at
Data do not include
sites proposed for
deletion.
NPL.
and PRP-lead.
sites.





SOURCES: EPA Superfund Budget Documents.
incorporates  many  of the operational characteristics of Superfund and numerous
points at which adjustments can be made.

     Conceptually,  the  model  uses  several standardized activity sequences  and
related cost and  FTE factors  to  estimate costs and schedules  for  new sites.
This  information  is  then  combined with  planning data  on current  sites  and
expected budget growth  of  program support elements to  produce a comprehensive
estimate of the cost to operate the Superfund Program.
                                     198

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            Progress Toward Implementing Superfund:  Fiscal Year 1988
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                                   199

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                  Exhibit 142-3
          EPA Superfund Staffing Requirements  in  Workyears
                               By Fiscal Year
1987 1988
Program Area Actual Actual
Hazardous Substance 1,056.8 1,186.5
Research 93.4 94.0
Response 963.4 1,092.5
Enforcement 764.5 928.4
Management and Support 353.0 482.9
Superfund Support 44.4
TOTAL 2,174.3 2,642.2
NOTE: ^ See section 9.1 for more information on the content
SOURCE: EPA Superfund Budget Documents.
1989 1990
Current Budget
Estimate Request
1,281.7 1,343.5
102.8 106.8
1,178.9 1,236.7
991.7 1,079.2
509.3 567.8
42.0 44.5
2,824.7 3,035.0
of these EPA program areas.

     143.1 Estimated Cost to Complete Current National Priorities List Sites

     The model has been  used to produce an estimate of  $18.6 billion as the cost
to complete  proposed and final sites on the existing NPL (Exhibit 14.3-1).  Major
considerations contributing to this estimate include:

     •    No new additions to the existing NPL which consists of both proposed
          and final sites;

     •    Five percent annual growth of Non-NPL Removals;

     •    Twenty percent annual decline  in the number of NPL Removals
          and preremedial site starts;

     •    RA  cost  factors will follow  a  pattern  similar  to what
          occurred  in FY87 and FY88;

     •    No annual growth for  all program  support and other agency
          elements  (except those tied to site-related activities);
                                      200

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  Exhibit 143-1
                      Estimate of  Outyear Liability to
                        Complete  the Existing NPL
                               (Dollars in Thousands)
                                              1987-1990         POST-FY90
      PROGRAM AREA                              TOTAL           ESTIMATE
    DIRECT SITE SUPPORT                       4,380,589.9     12,937,125.2

      -  SITE WORK                            3,196,537.3      7,881,148.1

         --  Removal Actions                    444,055.5        506,878.4
         --  Pre-Remedial Work                  175,256.0        431,983.8
         --  Engineering & Design Studies       813,053.8      1,686,510.9
         --  Remedial Actions                 1,677,964.3      5,255,775.0
         --  Other                               86,207.7

      -  SITE SUPPORT                         1,184,052.6      5,055,977.1


    PROGRAM SUPPORT                           1,152,420.5      4,000,905.3

    SITE-RELATED WORK                           344,202.0      1,647,214.7
    TOTAL SUPERFUND                           5,877,212.4     18,585,245.2
  SOURCES: EPA Superfund Budget Documents.
     •    Approximately half of all new site starts will involve Fund
          lead (i.e.,  the Trust Fund will pay 90 percent of the cost);
          and

     •    On average,  80  percent  of the Fund lead  sites,  50  percent
          of  the  PRP  lead sites,  and 100  percent  of the  Federal
          Facility sites will  require more than one RA before the site
          can be recommended for deletion from the NPL.

     These  factors  are  used  to  develop  the  current estimate  because  they
represent a  realistic  assessment  of how  the  program will  be run and what  is
expected  in  the  immediate   future.    The  estimate  of  long-term  Superfund
liabilities  is  based  on  planning data  for  active  sites  and  a  number  of
assumptions about future sites and events.  The actual site data are drawn


                                     201

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


directly  from CERCLIS, Superfund's  principal site  activity data  base.    The
assumptions  represent  a  combination  of  programmatic   directives  (planning
assumptions taken  from the Superfund Program Management Manual) and historic
performance averages.   As  a  result,  estimates produced by the model will  vary
over time (the CERCLIS  data used by the model  is updated every six  months  as  a
compromise between stability and accuracy) and in response to different  sets of
assumptions.  Subsequent annual editions of this Report  will  contain different
estimates.

     Assumptions that have the greatest effect on the  estimate include:

     •    The extent  of PRP  involvement:   To the  extent that  PRPs
          assume greater responsibility for cleanups,  Fund costs  will
          drop dramatically.   The $18.6  billion estimate  assumes  that
          in fiscal 1990 the  Fund will take the lead on approximately
          50 percent of all new RI/FS starts but that  takeovers  will
          rapidly increase the PRP portion of annual RA starts to  more
          than 70 percent by  fiscal 1997;

     •    The  ultimate  size  of the  NPL:    The  current  estimate
          addresses the existing NPL only; and

     •    Cleanup  costs:    Future changes in the  use  of  existing
          technologies, development of new technologies,  and overall
          experience may reduce costs.

As more information is  collected, every assumption  in  the  model,  including the
above, may be  adjusted to better depict future programmatic direction and refine
previous analysis.

     143.2 Major Program Elements Represented in the Model

     To provide  both  a better estimate  of the   cost  of  the  program and  the
flexibility needed to  estimate  the  costs of future initiatives,  the model
includes many components which represent  specific programmatic elements.

     Currently Active Sites

     Remedial efforts  are  underway  at most of the  sites on the  existing  NPL.
Remedial plans are being developed for another group,  leaving only 113 sites on
the existing  NPL that will be inactive  -- sites which  are  on the NPL but at
which efforts have not yet reached the Remedial Investigation/Feasibility Study
(RI/FS) phase --at the end of FY90.  Initial  remedial efforts are  expected to
be in progress at all  of these remaining  sites by the  end of FY92 .

     Data on  the active NPL sites are stored  in  Superfund's  program management
data base (CERCLIS).   A version of these  CERCLIS data  is incorporated into the
model  to  present the  most accurate  picture  of  planned activities at  active
sites.  Because all but a  few of  the  existing NPL sites  are  active  -- remedial
.efforts have  begun or are in planning  --  these  sites will constitute  a large
portion of any overall  liability  estimate.
                                      202

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     In addition to the planned remedial activities,  activities  associated with
the enforcement  program have a significant  impact  on the costs of addressing
Superfund sites.  The occurrences  of enforcement activities are estimated by  the
model using past  programmatic  experience  and several  standard  sequences of
activities,  each representing a  different  enforcement approach.   Enforcement
related variables within the model address not  only costs and FTEs,  but also  the
shifts in remedial costs when Superfund assumes responsibility  from,  or  passes
responsibility   to,   a  potentially  responsible  party.    As  with   remedial
activities, all  activity costs and FTEs are  estimated using Superfund planning
factors.

     Mew Site Starts

     The model estimates the occurrence of all activities and  related  costs  for
any NPL  site which  is currently inactive, as  defined above.   The  resource
estimate  included in  this  chapter is  constrained  to the existing  NPL.   An
estimate could be produced for a larger number of sites to estimate the cost of
future growth of the NPL.   To do this, activities  and related costs  would be
estimated for any number of new sites specified.

     For  the removal  and  preremedial  programs  in  general,  and  for  remedial
activities  at any  sites beyond  the existing NPL,  the model allows the user to
specify either  annual growth rates and an  overall  cap or an actual  number of
new starts  for each year for the  following  types  of  site/activity  starts:

     •    Non-NPL Removals;

     •    NPL-Removals;

     •    Preliminary Assessments (initiates  a  preremedial  program
          site start);  and

     •    Remedial    Investigation/Feasibility    Studies    (RI/FS)
          (initiates  a  remedial program site start).

     For the purposes of  the model,  site starts for  the removal,  preremedial,
and remedial programs are not linked, but there are  enforcement considerations
for each.   By "uncoupling" the program  areas,  it  is  possible  to estimate costs
for the existing program and for  a wide range  of  possible  programmatic changes
that affect the nature and  number of  new  sites.   Wide-reaching  programmatic
changes  of  this variety  may come  from any of  several sources.   Two  formal
sources of  change are revisions to the HRS and NCP.   Changes in  either document
could redefine  the number and types  of sites which  must  be  addressed by  the
program and the  objectives of such actions.

     Who is Responsible? - Who Pays?

     Aside  from the number of sites requiring cleanup  and the cost of individual
cleanups, the factors surrounding the  assumption of managerial and/or  financial
responsibility for a site have,  perhaps, the largest impact on the  costs  of  the
Superfund program.  There are many factors  involved  in this area,  including:

     •    Emphasis on and effectiveness of  the enforcement program;

                                      203

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
     •    Willingness of states to assume responsibility; and

     •    Cost sharing arrangements between Superfund and the states
          and between Superfund and the PRPs.

     The model accommodates each of these  factors  with one or more variables,
allowing the estimation of Superfund  liabilities for  a wide range of lead  and
cost sharing possibilities.   Variables include the:

     •    Proportion of sites addressed by each lead category;

     •    Number of PRP lead sites eligible for cost sharing and the
          portion of such costs assumed by the Fund;

     •    Number of sites that  are  owned/operated  by state or local
          governments;

     •    Number of  sites which follow each  of  several enforcement
          paths; and

     •    Expected success of cost recovery efforts.

     Choices among these variables may affect the duration of individual  cleanup
efforts and the program overall by  altering the mix of activity sequences which
are used.  The model includes  several different  sequences of activities, each
of  which is  intended  to  be  characteristic  of  one  path  that  site-related
activities might  take.   Each of the  sequences  involves different activities,
with  different durations  and  different  schedules.    A heavier  reliance  on
enforcement, for instance, will  result in longer elapsed times between the RI/FS
start  and Remedial Action (RA)  completion.   The  model responds  to lead  and
enforcement adjustments by changing the mix of these activity sequences.

     Factors Related to Remedial Action Costs

     The approach to  RA cost estimation revolves around the development of seven
technology categories,  each with a  unique  average  cost and expected  treatment
volume.  The technology categories were developed from research into the  Records
of Decision (RODs) from FY87 and FY88.

     RA cost adjustments within the model include  the:

     •    Proportion  of  sites  employing   a  particular technology
          category;

     •    Average  volume  of  contaminated media  addressed with  each
          technology category;  and

     •    Unit costs (cost per  cubic yard of contaminated media) for
          each technology.

     Adjustments  of  these  variables  make  it  possible  to  estimate the fiscal
impact of:

                                      204

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
     •    Policies  which   affect   the   selection  of  technological
          approach  (e.g.,  treatment vs.  containment);

     •    Changes   in  the   contaminants  found  on-site  (e.g.,  if
          remaining sites  have  higher  levels  of heavy metals  than
          prior sites, incineration would be less useful);

     •    Changes in technology  costs;  and

     •    Changes in site  size,  either  by technology (e.g.,  a policy
          to incinerate any site under  10,000 cubic yards) or across
          the  entire  range  (e.g.,  if all of the biggest  sites  have
          been done, what  is left  will  be smaller,  on average).

     Program Support and Other Agency Costs

     Although not directly related to site activities, these elements constitute
a large part of Superfund's budget and  are included in the model.  In general,
the approach used to  estimate these elements is  to  allow  each of them to grow
at  some specified  annual  rate.   Each  of  the  growth rates  can be  changed
independently,  allowing for more  rapid/slower  growth of  selected areas  as
programmatic demands  change.  In addition,  some  selected  support elements are
linked to the expansion/contraction of certain site-related activities and will
either increase or  decrease in size as those activities are  affected by other
variables.

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

     The second element in fulfilling the requirements  of  section 301(h)(l)(G)
of CERCLA 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 a GSA  IRCN  issued on
February 5, 1988, under  the provisions  of 41 CFR 201-45.6.   EPA has sought to
collect more comprehensive  information  for the  FY88 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)

          Interagency  Budget.   EPA transfers these  monies  to other
          federal departments and agencies from the  Trust Fund to fund
          their  activities  in  support  of EPA's Superfund  efforts.
          This  is  accomplished  through  an  interagency budget under
          Executive Order  12580.

          Site-Specific  Agreements.   EPA transfers these funds  to
          other federal departments and agencies from the  Trust Fund
          through site-specific  agreements.

     •    Individual Federal Department  or Agency Budgets


                                      205

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
          CERCLA-Specific  Funds.   These  funds are  budgeted by  the
          individual  departments  and  agencies  specifically   for
          Superfund activities and support as part of the President's
          annual budget submission.

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

     Exhibit  14.4-1  summarizes  reported  resource  needs   of other  federal
departments  and  agencies.    The following  information was  provided  by  other
departments and agencies to supplement the resource  estimates.

     •    Department of Defense.  The Department  of Defense (DOD) has  the
          authority  and responsibility  under  CERCLA  to   clean  up
          contamination  associated    with   its   past  activities.
          Beginning in 1984, DOD increased its emphasis on hazardous
          waste  cleanup by  establishing the  Defense Environmental
          Restoration  Program  (DERP)..    Under  this program,   DOD
          identifies, investigates,  and  cleans up contamination  and
          other  environmental  damage  on  its  installations  and  on
          formerly  used  properties.    One  element  of  DERP,   the
          Installation Restoration Program,  follows the procedures of
          the NCP in cleaning up contamination from  past activities.
          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 in 1989 and beyond.  Studies  have identified
          approximately 5,700  potential  sites  at 819 installations
          throughout the United States. Sites at 40 installations  are
          included or proposed for inclusion to the  NPL.

          DOD  estimates that  the total cost  of  the Installation
          Restoration Program  work will be  approximately  $11 to 14
          billion.  The uncertainty  in the total  funding requirement
          for this program  exists because many remedial investigations
          still must be completed, and many agreements have  yet to be
          signed with EPA and  state  agencies.

     •    Department of Energy.   No narrative provided.

     •    Department of Health and Human Services

          Agency for Toxic  Substances and Disease Registry.   During
          FY88, the Agency for Toxic  Substances and  Disease  Registry
          (ATSDR) planned  to complete 213 health assessments  at  NPL
          sites and 266 preliminary health assessments. Added to  the
          165 health assessments  completed by the beginning of FY88
          and  the  176  completed by state  cooperative   agreement
          projects,  this  accounts for the  completion of 820  health
          assessments or preliminary health  assessments.  CERCLA

                                      206

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         Progress Toward Implementing Superfund: Fiscal Year 1988
                          Exhibit 14.4-1
CERCLA  Resource Needs  and Interagency  Funding for
        Other Federal Departments and Agencies
           (dollars in thousands/full-time equivalent workyears)
Federal
Departments
and Agencies
Defense
Energy
Health and Human
Services
• ATSDR
• NIEHS
Justice
NASA
Transportation
• USCG
Interior
FEMA
Commerce
• NOM
Labor
• OSHA
Veterans Admin.
General Services
Administration
Tennessee Valley
Authority
Agriculture
TOTAL
1987 Actual
Dollars
Trust Agency
Fund Budget
375,900
47,663
32,439.3
0
10,473
--
4,023.3 6,615
707.6 6,900
1,173.7 1,255
1,819.9 666
281.3 0
0
150
200
--
50,918.1 439,349
FTEs
Agency
Budget
N/A
N/A
175.0
N/A
N/A
N/A
168.5
15.0
N/A
17.8
N/A
0
0.3
0
N/A
376.6
1988 Actual
Dollars
Trust Agency
Fund Budget
402,800
86,953
42,999.9
28,915.0
16,373.0
23,900
3,027.6 7,803
1,113.5 9,600
1,969.6 0
2,429.4 1,695
380.9 0
0 0
261
0
1,500
97,208.9 534,512
FTEs
Agency
Budget
1,060
N/A
175.0
N/A
163.0
0 N/A
171.5
24.0
23.0
17.8
15.5
0
4.0
0
N/A
1,653.8
 SOURCES:  EPA Superfund Budget Documents.
                            207

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               Progress Toward Implementing Superfund: Fiscal Year 1988
                            Exhibit 14.4-1 (continued)
      CERCLA Resource Needs and Interagency Funding for
              Other Federal Departments and  Agencies
                  (dollars in thousands/full-time equivalent workyears)
Federal
Departments
and Agencies
Defense
Energy
Health and Human
Services
• ATSDR
• NIEHS
Justice
NASA
Transportation
• USCG
Interior
FEMA
Commerce
• NOAA
Labor
• OSHA
Veterans Admin.
General Services
Administration
Tennessee Valley
Authority
Agriculture
TOTAL
1989 Operatins Plan
Dollars FTEs
Trust Agency Agency
Fund Budget Budget
500,000 N/A
112,839 N/A
44, 500.0 -- 175.0
21,915.0 -- N/A
16,700.0 — 167.0
26,000.0 N/A
4,948.2 8,639 173.5
1,253.5 24,700 23.0
1,879.6 0 23.0
2,280.1 1,024 20.8
1,008.2 0 15
0 5,000 0
0 19
0 — 0
2,500 N/A
94,484.6 680,702 616.3
1990 Budget Reouest
Dollars FTEs
Trust Agency Agency
Fund Budget Budget
N/A
181,904 N/A
44,500.0 — 250
21,915.0 — N/A
19,200.0 -- 171.0
30,000.0 N/A
4,948.2 — N/A
1,253.3 -- 13
1,879.6 0 23.0
2,280.1 1,024 20.8
1,008.2 — 12
0 5,000 0
N/A
0 — 0
N/A
96,984.6 217,928 489.8
1987-1990 Total
Dollars
Trust Agency
Fund Budget
1,278,700
429,359
164,439.2
72,745.0
62,746.3
79,900.0
16,947.3 23,057
4,328.1 41,200
6,902.5 1,255
8,809.5 4,409
2,678.6
0 10,000
411
200
4,000
339,596.2 1,872,491
SOURCES:  EPA Superfund Budget Documents.
                                    208

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           Progress Toward Implementing Superfund: Fiscal Year 1988
     mandates that health assessments  be  performed for all 951
     sites on the  NPL by the  end of FY88.   The  remaining 131
     assessments are scheduled  for  completion during the first
     quarter  of   FY89.     ATSDR   also   completed  two  pilot
     studies/investigations on selected populations during FY88
     and initiated 22 others.  It also provided over 2,200 health
     consultations at remedial sites.

     In  compliance with  section  104(i)(3)  of CERCLA,  which
     requires ATSDR  to prepare  toxicological profiles  on the
     first  100  most  hazardous substances  found  at  Superfund
     sites,  ATSDR completed  25  during  FY87  and planned  to
     complete another 25 during FY88.   The Agency also planned
     to conduct at least 1,000  health  consultations to private
     or public health care providers in the provision of medical
     care and testing of exposed individuals.

     ATSDR planned to  finalize the  National  Registry Proposal
     and Procedures for Persons Exposed to Toxic Substances, as
     mandated under CERCLA.   Also,  ATSDR continued discussions
     with  other  agencies  regarding  toxicological  profiles and
     health assessment research.

     National Institute of  Environmental  Health Sciences.   The
     Superfund Basic Research Program at the National Institute
     of Environmental Health  Sciences  (NIEHS)  is  authorized by
     the 1986 Superfund amendments and complements the existing
     applied research  efforts underway at  EPA and ATSDR.   It
     differs from  the  research sponsored by  other agencies in
     that it will combine basic research in ecology, engineering,
     and hydrogeology  into  a biomedical  research  program core
     designed to  provide  a broader and more  detailed  body of
     scientific information to  be used by  federal,  state, and
     local agencies and by private organizations and industry in
     making  decisions  related  to  the  management  of hazardous
     substances.

•    Department of Justice.   The  Department  of Justice  (DOJ) has two
     objectives under  the  Superfund program:   to  defend the
     program from legal challenges and to compel PRPs to comply
     with  the  law.   Because of  limited resources  to support
     Superfund over the  long term, enforcement is one of  the keys
     to the success of the program.

     DOJ plays an integral role  in the  Superfund program through
     judicial enforcement   actions  to  recover cleanup  costs,
     impose civil  penalties, and compel PRPs to perform cleanups.
     To this end, DOJ's three priorities for Superfund litigation
     are:  (1) lodging and entering  consent  decrees that provide
     for privately funded remedial action;  (2)  injunctive relief
     actions to  compel privately funded remedial action; and (3)
     cost  recovery lawsuits to recoup Trust  Fund  monies spent
     cleaning up sites.

                                 209

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       Progress Toward Implementing Superfund:  Fiscal Year 1988
National Aeronautics and Space Administration .  The National Aeronautics
and Space Administration  (NASA)  projects that in FY90  its
resource needs for  cleaning  up its properties will be  $30
million.    Studies,  assessments,   and  design  costs   are
approximately $2.09 million;  RI/FS  costs are  $2.75 million.
For cleanup projects  costing less  than $150,000 each,  the
total  amount  needed  is   $2.88  million.     For projects
exceeding $150,000  each,  the total costs are  estimated at
$22.28  million for activities focusing on  air pollution
abatement, asbestos management, rehabilitation/ replacement
of PCB transformers, hazardous waste monitoring and control,
replacement    of   underground    storage    tanks,     and
rehabilitation/upgrading of  treatment  systems.

Department of Transportation.    The Department of  Transportation
(DOT) estimates that it will  use  fiscal 1989  funds from  its
department budget for its CERCLA-related activities in  the
Federal  Aviation Administration  (FAA), the Research  and
Special Programs  Administration (RSPA),  the U.S. Coast Guard
(USCG),  and  the Maritime  Administration   (MARAD).     The
substantial  increase  in  total  program  needs  over  FY87
results  from  an  expansion of  the  FAA Pollution Abatement
Program, which averages between  70 percent  and  80 percent
of DOT's total needs per year.  The decrease in  total work
years results  from  adjusting USCG  numbers to  reflect only
individual agency budget figures.

A  Trust  Fund appropriation through  general Interagency
Agreements   enables  USCG   to   maintain   its   response
capabilities, ensures that CERCLA  financial  responsibility
requirements  are  met,  trains emergency response personnel
using  program modules  and   simulation  drills, staffs  the
CERCLA  component  of the  National  Response  Center,   and
maintains  chemical  information  systems  and  records   of
characteristics for certain  chemicals.

FAA  receives  no  monies from  the  Superfund.   Its CERCLA
activities will focus on hazardous waste cleanup at closed
facilities and other cleanup  efforts to remove asbestos  and
PCBs.

RSPA supports the Superfund program through its rulemaking,
technical   support,    information   and   planning   data
development,  and  emergency response support  activities.

USCG is  a major supporter of the Superfund program through
its role as the predesignated  Federal  On-Scene Coordinator
in the  Coastal Zone for responding to  actual or  threatened
releases  of hazardous  substances.    It also  must address
pollution  abatement related to  the  operation of its  own
facilities.
                            210

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       Progress Toward Implementing Superfund:  Fiscal Year 1988
MARAD  receives   no  monies  from  the  Superfund.    The
Administration is a de minimis third party PRP for a cleanup
project at  a  nuclear waste site in Maxey Flats,  Kentucky,
where waste from the nuclear ship SAVANNAH was  deposited.
A one-time funding  allocation is projected  for FY89.

Department of the Interior.   Each  of the nine  bureaus and  four
territorial elements of the Department of the Interior (DOI)
has  provided  support  to  the  Superfund  program,   mostly
assisting  the  National Response  Team  and  the Regional
Response Teams.  DOI's role in the program focuses on three
general areas:

Response Management,  including RRT assistance activities,
incident-specific activities, and NPL site remedial response
activities;

Emergency  Response  Preparedness,  including  RRT partici-
pation, regional RRT workgroups, and RRT  support; and

Trust Resources/Damage Assessment, including coordination
of  natural resource  trustee concerns,  natural resource
damage  assessment  briefings,  and settlements  of  trustee
resources.

Federal Emergency Management Agency.   The enactment  of SARA  in
1986 made  many  of the voluntary preparedness and planning
activities  of  the  Federal  Emergency Management   Agency
(FEMA),  including   activities  required  by  Title   III,
ineligible  for  funding  under the  Superfund budget  after
September  30, 1987.   To  continue the  ongoing  Superfund
assistance  to state and local  governments  and  to  support
their  efforts  to  implement  Title  III,  FEMA,   in  FY88,
consolidated  its   funding  requests  under   two  separate
authorizations of appropriation.  Funding for all Superfund
activities  was  requested  under  the  Superfund Interagency
Budget,  and  the  remainder of  FEMA's  hazardous  materials
activities,  including  Title  III,  was  incorporated  into
FEMA's own operating budget (under its  Earthquake and Other
Hazards Budget).  Thus, no additional funds were requested
under Section 301(h)(l)(G)  to carry out Superfund activities
after FY87.

Department of Commerce.  The National Oceanic and Atmospheric
Administration    (NOAA)    carries    out   many   of   the
responsibilities of the Department of Commerce  (DOC)  under
CERCLA.    NOAA's Superfund  program  goals   are:    (1)  to
strengthen  and  accelerate  technologies to  plan for, and
respond  to hazardous  substance  releases in  coastal and
marine  areas;  and  (2)  to  assist  EPA  in identifying,
evaluating, and mitigating the adverse  effects of hazardous
substances  on  natural  resources  in  coastal  and  marine
ecosystems.

                            211

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       Progress Toward Implementing Superfund:  Fiscal Year 1988
These goals are addressed primarily through NOAA's efforts
to  build  an  effective  network  of  Scientific  Support
Coordinators and core support groups to assist Federal On-
Scene  Coordinators  in  responding to  hazardous  substance
releases  into coastal  or  marine waters.    It also  has
developed  computerized  contingency plans for major U.S.
ports.

NOAA also acts on behalf of the Secretary of Commerce as a
federal trustee for natural resources  in coastal and marine
areas  affected by  hazardous  substance  releases.    NOAA
Coastal Resource Coordinators,  funded  through Superfund and
assigned  to  EPA Regional  offices, assist  the Agency in
evaluating natural  resource  concerns  at coastal hazardous
substance release sites and in improving coordination with
federal and state natural resource trustees.  The resource
estimates do not include those resources necessary to meet
NOAA's role as a federal trustee for natural resources.

Department of Labor.  Funds appropriated under general lAGs will
allow  the Occupational  Safety and Health  Administration
(OSHA) of the  Department of Labor (DOL) and states operating
OSHA-approved  plans to continue  providing EPA  and other
response  personnel  with  technical assistance  to  protect
workers at Superfund sites, implementing the worker safety
program at Superfund sites, and supporting the National and
Regional Response Teams.

OSHA conducts inspections at Superfund sites to ensure that
employers  are  in  compliance   with   all  applicable  OSHA
standards, including the standard  for  employees engaged in
hazardous waste operations,  as mandated by section 126 of
CERCLA.    In  FY90,  OSHA  will  implement  a  training/
certification program as required  by CERCLA section 126.

OSHA performs  laboratory  analyses of  samples collected at
Superfund  site inspections  and maintains  and calibrates
technical  equipment used  for  these  inspections.   OSHA's
analytical laboratory also maintains a computerized system
for tracking hazardous waste inspection activity.  In FY90,
OSHA will perform  up  to  three  technical  assistance site
visits  and  will   update  the  Agency's  Hazardous  Waste
Reference Manual.   As a member of the National Response Team
and the associated Regional Response Teams, OSHA assists the
teams  in meeting their annual workplans.

Veterans Administration.    Prior  to  FY89,  no  funds had been
specifically budgeted for  Superfund cleanups.  In FY89 and
subsequent years, the Veterans Administration  (VA) will be
budgeting  for  $5 million  to meet projected costs.   At the
present time, the VA is  a PRP at two sites  (Baldwin, Florida
and Holden, Missouri).

                            212

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       Progress Toward Implementing Superfund: Fiscal Year 1988
Department of Agriculture.   Congress  appropriated $2  million in
FY88 and $5 million  in FY89  for hazardous waste management
activities at the Department  of Agriculture (USDA).  Because
hazardous waste management activities  comprise both CERCLA
and RCRA compliance, USDA split the  monies between the two
programs  75/25  (CERCLA/RCRA)  in FY88  and 50/50  in FY89.
USDA intends  to  dedicate its Superfund effort to planning
and  remedial action efforts at abandoned  mines  for  the
Forest  Service  and  to  various  other activities by  the
Agricultural  Research   Service,  Forest  Service,  Rural
Electrification Administration,  and Animal and Plant Health
Inspection Service.

General Services Administration .  During FY88,  the General Services
Administration  (GSA) conducted  PAs  for 18  GSA  facilities
that appeared on  the federal facilities docket.   GSA does
not anticipate that further work will be performed at these
18  sites.   Therefore,  no  additional  resources  have been
specifically  identified  for  CERCLA activities.   Resources
for environmental studies/corrective projects,  however, are
included in  the  GSA  budget  and can be utilized  for CERCLA
studies/corrective projects, if  necessary.    In addition,
GSA  currently    is   involved   in   five   Superfund   site
investigations in which  it  is  a PRP;  as  a  result,  it may
incur third-party PRP costs  in  future  years.

Tennessee Valley Authority.   No narrative provided.
                            213

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           Progress Toward Implementing Superfund:  Fiscal Year 1988
EPA Headquarters and Regional Superfund Offices
     Hsadquartars
     Environmental Protection Agency
     Office of Solid Wast* and Emergency Response
     401 H Street, S.W.
     Washington, DC 20460
     (202) 3(2-4610
     Region 1
     Environmental Proteetlon Agency
     John f. Kennedy Federal funding
     Room 2203
     Beaton, MA 02203
     (617) 566-3718

     Region 2
     Environmental Prateetlon Agency
     26 Federal Plaza
     New York. NY 10273
     (212) 264*2828

     Region 3
     Environmental Proteetlon Agency
     •41 Chestnut Street
     Philadelphia, PA 19107
     (215) 897-9600
    Region 4
    Environmental Proteetlon Agency
    348 Courtland Strset, N.E.
    Atlanta, OA 30368
    (404) 347-4727

    Region 8
    Environmental Proteetlon Agency
    230 South Dearborn Street
    Chicago, IL 60604
    (312) 383-2000
Region 6
Environmental Protection Agency
1448 Ross Avenue
12th Floor, Suite 1200
Dallas, TX 76270
(214) 688-6444

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

Region 8
Environmental Protection Agency
999 18th Street
Suite 800
Denver, CO 80202-2408
(303) 293-1603

Region 9
Environmental Proteetlon Agency
218 Fremont Street
San Francisco, CA 94108
(418) 974-8071

Region 10
Environment*! Protection Agency
1200 Sixth Avenue
Seattle,  WA 96101
(206) 442-8810
                                    214

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX A

             STATUS OF REMEDIAL INVESTIGATIONS, FEASIBILITY STUDIES,
            AND REMEDIAL ACTIONS IN PROGRESS ON SEPTEMBER 30, 1988
     Appendix A satisfies the combined statutory requirements of CERCLA sections
301(h)(l)(B)  and (F).    This  appendix provides  a report  on  the  status and
estimated completion date of all remedial investigation/feasibility study  (Rl/FS)
and remedial action (RA) Title I  projects in progress  at the end of FY88.  This
appendix also  provides  notice of RI/FSs that  EPA presently believes will not
meet  its  previously published schedule for completion, as  well as  the new
estimated dates of completion, as required by  section 301(h)(1)(C).  Estimated
completion dates for these projects were previously published  in Appendix D of
the FY87 Report  entitled Progress  Toward Implementing Superfund:  Fiscal Year
1987.  In addition to the statutory requirements,  this  appendix lists remedial
projects begun  in FY88  that were ongoing at the  end  of FY88.   For a complete
discussion of the stages  of the remedial process,  see section 3.3 of this  Report.
Column 1:   Region
Column 2:   State
EPA Region in which the site is located.  See final exhibit
in report text for  the  locations  of the 10 EPA Regional
offices.

State in  which the site is located.  See Exhibit 5.0-2 for
the distribution of National Priorities List (NPL) sites
throughout the States and territories.
Column 3:  Site Name  Name  of  the site,  as  listed on  the  NPL, Supplementary
                      Lists and .Supporting Materials, June 1988, OERR.

Column 4:  Location   Location of the site, as listed on the NPL.

Column 5:  Activity   Type of project in progress on September  30, 1988.

Column 6:  Lead       The entity leading the activity, as follows:

                      • EP:   Fund-financed   with    EPA   employees
                              performing the project, not contractors;

                      • F:    Fund-financed  and Federal-lead
                              by   the   Superfund   remedial
                              program;

                      • FE:   EPA Enforcement program-lead;

                      • FF:   Federal Facility-lead;

                      • PRP:  PRP-lead and -financed;
                                      A-l

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX A

             STATUS OF REMEDIAL INVESTIGATIONS, FEASIBILITY STUDIES,
            AND REMEDIAL ACTIONS IN PROGRESS ON SEPTEMBER 30, 1988
                                   (continued)
                      • PS:   PRP-financed work performed by the PRP
                              under  a  state  order  (may  include
                              federal financing or federal oversight
                              under an enforcement document);

                      • S:    State-lead and Fund-financed; and

                      • SE:   State enforcement-lead (may include
                              federal financing);  State-lead and
                              -financed, no Fund money.

                      0  (Other),  SN (State-lead and  -financed,  no
                      Fund  money),   and  SR   (State-ordered  PRP
                      response)  activities  are excluded from this
                      status  report because  they  do not  include
                      federal financing.

Column 7:  Funding    The date on which funds were allocated for the activity.
           Start      The funding start  dates of several projects listed in this
                      appendix differ from the dates  that were  published in the
                      FY87  Report.    For  this appendix,  such  projects  were
                      assumed to  be  the same if the  funding  start dates  were
                      within the same fiscal year.  Some  projects with  a status
                      of "new" have a funding start date prior to  FY88  because
                      the Region developed an estimated completion  date for the
                      project in FY88, rather than in the fiscal year  in which
                      funds were allocated.   Thus,   these  projects  were  not
                      listed in the FY87 Report.

Column 8:  Previously For projects ongoing at the end of FY87  that continued
           Published  into FY88, the quarter of the planned  completion  date for
           Completion the activity, as of  9/30/87, the end of FY87 .  This column
           Schedule   is blank  for projects  that  were not begun  until  FY88.
                      For  projects  listed  in  Appendix  D  of  the  FY87  Report
                      without an  estimated  completion date, such  as the RI/FS
                      at the Silresim Chemical Corp.,  in  Lowell, Massachusetts,
                      * * * * appears in the Status column.

Column 9:  Present    The quarter of the planned completion date for the
           Quarter    activity, as of 9/30/88.  CERCLIS  compiled this
           Estimated  information on March 6, 1989.
           Completion
                                      A-2

-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX A

             STATUS OF REMEDIAL INVESTIGATIONS, FEASIBILITY STUDIES,
            AND REMEDIAL ACTIONS IN PROGRESS ON SEPTEMBER 30, 1988
                                   (continued)
Column 10: Status     Status of the project,  as  of  the  end of  FY88.

                      On-schedule projects  are designated by a zero  (0).

                      Projects  that are  behind  schedule  are  designated by  a
                      numeral indicating the number  of quarters that the project
                      is behind schedule  and a minus  sign (e.g.,  -4).

                      Projects  that  are ahead of schedule are  designated by  a
                      numeral indicating the number  of quarters that the project
                      is ahead  of schedule  (e.g., 4).

                      Projects for which EPA has not estimated a completion date
                      are  designated  by an  asterisk  (*) .   Projects that were
                      begun in  FY88 are described as  new  in the status column.

                      For  example,  the RA  at the  Beacon Heights Landfill  in
                      Beacon Falls,  Connecticut  was new this  fiscal year;  the
                      RI/FS  at  the  Kellogg Deering Well Field  in  Norwalk,
                      Connecticut was  one quarter behind  schedule, as  compared
                      to its estimated date  of completion at the  end of FY87.
                                      A-3

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-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1988


                                  APPENDIX B

                         RECORD OF DECISION ABSTRACTS


     This appendix provides  detailed  descriptions of FY88 feasibility  studies
(FSs), as required by CERCLA  section 301(h)(1)(A).   These descriptions are based
on Records of Decisions  (RODs)  signed from  October 1, 1987, through  September
30, 1988. This  appendix includes 149 ROD abstracts.  Two of these  ROD abstracts
represent sites  with more than one remedial action:  the abstract for the  Charles
George  Landfill in Massachusetts represents  two  remedial actions,  and  the
abstract for the San Gabriel Valley site  in California, which represents three
remedial actions.  Thus, EPA signed  152 RODs in FY88, which are  summarized in
this appendix by 149 abstracts.

     The appendix summarizes  both first  and subsequent RODs; subsequent RODs  are
identified by an asterisk following the site name  (e.g., Cannon Engineering*).

     Each abstract  provides background  information  on  the  Superfund site,
including the date on  which EPA signed the ROD,  former use  of the  site,  type of
operation, contaminants of concern, and previous  clean-up actions.  Each abstract
also includes a description of the remedial alternative selected in the  ROD  and
provides information on  the  use of alternative  or resource recovery  treatment
technologies and on the performance standards or goals for  the site.   All sites
abstracted in the appendix  are listed  alphabetically according to  the site name
and are grouped by EPA Region.
                                     B-l

-------
                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   APPENDIX B

                          RECORD OF DECISION ABSTRACTS
                                     (continued)
                        Site	   State   Region   Page
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.
Cannon Engineering*
Charles George Landfill (LF)*+
Groveland Wells
Iron Horse Park
Keefe Environmental Services*
Landfill & Resource Recovery
Laurel Park
Old Springfield LF
Rose Disposal Pit
Yaworski Lagoon
American Thermostat
Asbestos Dump
Beachwood/Berkeley Well
Brewster Well Field*
Burnt Fly Bog*
Ewan Property
GE Wiring Devices
Kin -Buc LF
Lipari LF*
Love Canal*
Love Canal/93rd Street School*
Ludlow Sand and Gravel
Marathon Battery*
Montgomery Township Housing Development*
Nascolite
Old Bethpage
Reich Farm
Ringwood Mines/LF
Rocky Hill
Tabernacle Drum Dump
Upjohn Manufacturing Company
York Oil
Aladdin Plating
Ambler Asbestos Piles
Avtex Fibers
MA
MA
MA
MA
NH
RI
CT
VT
MA
CT
NY
NJ
NJ
NY
NJ
NJ
PR
NJ
NJ
NY
NY
NY
NY
NJ
NJ
NY
NJ
NJ
NJ
NJ
PR
NY
PA
PA
VA
1
I
I
I
I
I
I
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
— &* •
B-7
B-8
B-9
B-ll
B-12
B-13
B-14
B-15
B-16
B-17
B-18
B-19
B-20
B-21
B-22
B-23
B-24
B-25
B-26
B-27
B-28
B-29
B-30
B-31
B-32
B-33
B-34
B-35
B-36
B-37
B-38
B-39
B-40
B.-41
B-42
* subsequent ROD
+ represents  more than one remedial  action
                                       B-2

-------
Progress Toward Implementing Superfund:  Fiscal Year 1988
                   APPENDIX B

         RECORD OF DECISION ABSTRACTS
                    (continued)
       Site__
State    Region   Page
36.
37.
38.
39.
40.
41.
42.
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.
71.
72.
73.
74.
75.
Bendix
Berks Sand Pit
Chisman Creek*
Delaware Sand & Gravel
Dorney Road LF
Douglassville Disposal*
Drake Chemical*
Fike Chemical
Henderson Road
Kimberton
L.A. Clarke & Son
Middletown Air Field
New Castle Steel
Ordnance Works Disposal
Palmerton Zinc*
Rhinehart Tire Fire
Southern Maryland Wood
Tyson's Dump*
Voortman Farm
West Virginia Ordnance*
Westline*
Wildcat LF
Airco
Alpha Chemical
Brown Wood Preserving
Celanese Fibers Operations
Chemtronics
Flowood
Goodrich, B.F.
Independent Nail*
National 'Starch
Perdido Groundwater Contamination
Wamchem
Zellwood
Allied/Ironton Coke
Belvidere LF
Coshocton LF
Eau Claire Municipal Well Field*
Forest Waste Disposal*
Fort Wayne Reduction
PA
PA
VA
DE
PA
PA
PA
WV
PA
PA
VA
PA
DE
WV
PA
VA
MD
PA
PA
WV
PA
DE
KY
FL
FL
NC
NC
MS
KY
SC
NC
AL
SC
FL
OH
IL
OH
WI
MI
IN
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
• .^»i—
B-43
B-44
B-45
B-46
B-47
B-48
B-49
B-50
B-51
B-52
B-53
B-54
B-55
B-56
B-57
B-58
B-59
B-60
B-61
B-62
B-63
B-64
B-65
B-66
B-67
B-68
B-69
B-70
B-71
B-72
B-73
B-74
B-75
B-76
B-77
B-78
B-79
B-80
B-81
B-82
                      B-3

-------
Progress Toward Implementing Superfund:  Fiscal Year 1988
                  APPENDIX B

        RECORD OF DECISION ABSTRACTS
                    (continued)
       Site
State    Region   Page
76.
77.
78.
79.
80.
81.
82.
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101.
102.
103.
104.
105.
106.
107.
108.
109.
110.
111.
112.
113.
114.
IMC/Terre Haute
Kununer Sanitary LF*
LaSalle Electrical Utilities*
Long Prairie
Mason County LF
Mid-State Disposal LF
NL/Taracorp/Golden Auto Parts
Ninth Avenue Dump
Oak Grove LF
Petersen Sand & Gravel
Poer Farm
Pristine
Republic Steel Quarry
South Andover
Summit National
U.S. Aviex
United Scrap Lead
Velsicol Chemical
Waste Disposal Engineering
Atchison/Santa Fe (Clovis)
Bailey Waste Disposal
Brio Refining
Dixie Oil
French Limited
Gurley Pit*
Industrial Waste Control
Koppers Texarkana
North Cavalcade Street
Odessa Chromium I*
Odessa Chromium II*
Old Midland Products
Sand Springs*
Sol Lynn
Sol Lynn*
South Cavalcade
South Valley/Edmunds Street
South Valley/SJ-6*
South Valley/PL- 83*
Stewco
IN
MN
IL
MN
MI
WI
MN
IN
MN
IL
IN
OH
OH
MN
OH
MI
OH
IL
MN
NM
TX
TX
TX
TX
AR
AR
TX
TX
TX
TX
AR
OK
TX
TX
TX
NM
NM
NM
TX
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
i ^. .
B-83
B-84
B-85
B-86
B-87
B-88
B-89
B-90
B-91
B-92
B-93
B-94
B-95
B-96
B-97
B-98
B-99
B-100
B-101
B-102
B-103
B-104
B-105
B-106
B-107
B-108
B-109
B-110
B-lll
B-112
B-113
B-114
B-115
B-116
B-117
B-118
B-119
B-120
B-121
                      B-4

-------
Progress Toward Implementing Superfund:  Fiscal Year 1988
                   APPENDIX B

         RECORD OF DECISION ABSTRACTS
                    (continued)
       Site
State    Region
115.
116.
117.
118.
119.
120.
121.
122.
123.
124.
125.
126.
127.
128.
129.
130.
131.
132.
133.
134.
135.
136.
137.
138.
139.
140.
141.
142.
143.
144.
145.
146.
147.
148.
149.
United Nuclear Corporation
Arkansas City Dump
Big River Sand
Cherokee County/Galena
John Deere Dubuque Works
Fulbright/Sac River LFs
Hastings Ground Water/Colorado Avenue
Hastings Ground Water/FAR-MAR-CO*
Midwest Manufacturing/North Farm
Minker/Stout/Romaine Creek*
Shenandoah Stables
Syntex Verona
Times Beach*
Anaconda Smelter/Mill Creek
Broderick Wood Products
California Gulch
Central City/Clear Creek*
Indian Bend Wash
Lorentz Barrel & Drum
MGM Brakes
Motorola 52nd Street
Operating Industries*
Operating Industries*
Or dot LF
San Gabriel Valley (Areas 1, 2, and 4)+
Selma Pressure Treating
South Bay Asbestos
Tucson International Airport Area
Commencement Bay/Nearshore
Commencement Bay/Tacoma*
Frontier Hard Chrome*
Frontier Hard Chrome
Gould
Martin Marietta
Pacific Hide & Fur
NM
KS
KS
KS
IA
MO
NE
NE
IA
MO
MO
MO
MO
MT
CO
CO
CO
AZ
CA
CA
AZ
CA
CA
Guam
CA
CA
CA
AZ
WA
WA
WA
WA
OR
OR
ID
6
7
7
7
7
7
7
7
7
7
7
7
7
8
8
8
8
9
9
9
9
9
9
9
9
9
9
9
10
10
10
10
10
10
10
B-122
B-123
B-124
B-125
B-126
B-127
B-128
B-129
B-130
B-131
B-132
B-133
B-134
B-135
B-136
B-137
B-138
B-139
B-140
B-141
B-142
B-143
B-144
B-145
B-146
B-147
B-148
B-149
B-150
B-151
B-152
B-153
B-154
B-155
B-156
                      E-5

-------
                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                  CANNON ENGINEERING, MA
                                    First Remedial Action - Final
                                          March 31, 1988
ROD ABSTRACT
      The Cannon Engineering Corporation (CEC) facility is located in a small industrial park in the western
part of the Town of Bridgewater, Plymouth County, Massachusetts.  The four-acre  site  is bordered by
industrial developments to the north and east and a wooded lowland to the south and west.  A wetland area
lies south and  west  of the site.  CEC, which  has owned the property since  1974, handled, stored, and
incinerated chemical  waste onsite from 1974  to 1980. EPA conducted site investigations between 1980 and
1982, and in October 1982, Massachusetts contracted for the removal of sludge and liquid waste from onsite
tanks  and drums.  In January 1988,  EPA provided for the removal  and disposal of numerous hazardous
materials abandoned at the site. This remedial action addresses  three discrete areas of soil and sediment
contamination located in  the northwestern and southern portions of the  site, and the buildings, tanks, and
other  contaminated structures onsite.  The volume of contaminated soil is estimated to be 325 yd .  The
primary contaminants of concern affecting the ground water,  soil, and debris are VOCs including benzene,
TCE,  and vinyl chloride, and other organics including PCBs and PAHs.

      The selected remedial action for this site includes:  access restrictions; excavation and onsite treatment
of VOC-contaminated soil by thermal aeration,  and excavation and offsite treatment of PCB-contaminated
soil by incineration; decontamination,  removal, and disposal of contaminated buildings, tanks, and structures;
additional soil sampling to assess effectiveness; ground water monitoring and implementation of a water quality
monitoring program to assess natural  attenuation of contaminants;  and institutional controls to restrict onsite
ground water use. The estimated  present worth cost for this remedial  action  is between  $3,400,000, and
$4,505,000 with present worth O&M of $700,000.

PERFORMANCE STANDARDS OR GOALS: Target cleanup goals for soil  include benzene 55 ug/kg, and
TCE 71 ug/kg (based on leaching potential  into ground water as determined using the Organic Leaching
Model), and PCBs 9 mg/kg (based on risk levels).  Target goals  for  ground water  include  benzene 5 ug/1
(MCL), TCE 5 ug/1  (MCL), and vinyl chloride 2 ug/1.

INSTITUTIONAL CONTROLS:  Deed and land restrictions will be implemented to prevent the use of onsite
ground water.
                                              B-7

-------
                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                               CHARLES GEORGE LANDFILL, MA
                              Third and Fourth Remedial Actions - Final
                                         September 29, 1988
ROD ABSTRACT
      The Charles George Landfill (CGL) site is located approximately one mile southwest of the Town
of Tyngsborough, Massachusetts. The 70-acre site is bounded by Flint Pond Marsh (wetland area) and Flint
Pond to the east, Dunstable Brook to the west, and the Cannongate Condominium complex to the southeast.
Land use in the vicinity of the site is predominantly rural and  residential but also includes some light industry
and seasonal livestock grazing.  The landfill contains municipal waste disposed of onsite from the mid-1950s
until the landfill closed in 1983 by order of the Massachusetts Attorney General.  Hazardous industrial waste
was also disposed of primarily in the western  area of the  site from 1973 until at least 1976.  The site came
to the attention of the Massachusetts Department  of Environmental Quality Engineering (DEQE) when the
deep bedrock wells in use by the Cannongate Condominium complex became contaminated with VOCs.  The
DEQE ordered  the wells closed in 1982.  EPA conducted ground water monitoring in 1981 and 1982, and
also  undertook emergency removal actions beginning in August 1983 and continuing through March 1984.
Presently the site has a thin soil cover, 2 surface water and leachate lagoons, 2 leachate collection systems,
1 recirculating pump station, and 12  shallow gas vents.  Construction  of a full synthetic landfill  cap  was
addressed in a previous ROD and should begin in early 1989. This ROD encompasses the third and fourth
operable units and focuses on the control and cleanup of contaminants that have spread or are spreading from
the site, including the treatment of leachate collected as part of the cap system. Investigations have identified
contaminated  ground water in overburden, shallow  bedrock, and deep bedrock zones.   In addition, an
estimated  500 yd of sediments require remediation, and  vent emissions from the landfill  are contaminated
with  a wide array of VOCs. The primary contaminants of concern affecting the ground water, sediments and
air, are VOCs including benzene and TCE, organics including PAHs, and metals including arsenic.

      The selected remedial action for this site includes:  extraction and treatment of shallow ground water
plumes and leachate collected from the landfill cap system  using biological treatment, metals precipitation and
carbon adsorption with onsite discharge of the treated water into the aquifer or offsite discharge into nearby
surface water;  collection and  incineration  of landfill  vent gas  emissions; excavation  and solidification of
approximately 500 yd  of contaminated Dunstable Brook sediments  and placement beneath  the Phase II
landfill cap; ground  water monitoring and access restrictions.   The estimated present worth cost for this
remedial  action is $11,320,000 which includes  O&M costs of  $601,000.

PERFORMANCE STANDARDS OR GOALS:  The target cleanup levels for ground water are benzene and
TCE 0.005 mg/1, cadmium 0.010 mg/1, and arsenic and silver 0.05  mg/1,  all based on MCLs.  Contaminants
in the deep aquifer cannot  practicably be extracted but will attenuate to health-based levels within a depth
of 500 feet.  The cleanup goal for sediments requires PAH levels of less than 1.0 mg/kg, based on a risk level
of 4 x 10~6. Target levels for 12 VOCs in vent emissions are  listed based on a 1 x 10   cumulative risk level.

INSTITUTIONAL CONTROLS: Not  applicable.
                                               B-8

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     GROVELAND WELLS, MA
                                        First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The 850-acre Groveland Wells site is located in the Town of Groveland, Essex County, Massachusetts,
within the lower Johnson Creek drainage basin.  The site includes the watershed and aquifer which recharge
two municipal supply wells, Station Nos. 1 and 2, and three  known sources of soil, surface water, and ground
water contamination:  the Valley site, the A.W. Chesterson site, and the Havenhill Municipal Landfill site.
This remedial action  addresses  source  control  at the Valley  site.  The remaining operable units of the
Groveland  Wells site  will be  addressed in subsequent remedial actions.  The Valley  site operable unit is
located in the far northwestern section of the Town of Groveland,  and is bordered to the north  and south
by residences within 100 feet of the site.  The Town of Groveland's  municipal water supply well, Station No.
1, is located approximately 3,500  feet northeast and downgradient of the Valley site, and is currently being
treated to remove VOCs as part of an initial remedial measure by EPA.  The Valley Manufactured Products
Company (Valley) began operating  a metals  and plastic parts manufacturing business in 1963 on  a 1.5-acre
parcel of property owned by Groveland Resources Corporation (GRC).

      The Valley site area consists  of the  land  within and immediately  adjacent to the GRC property
boundaries and contains three subsurface  disposal  systems, an oil storage and recovery system consisting of
six underground tanks and a 55-gallon drum storage area, both of which were used to store cutting oils and
solvents such as TCE and methylene chloride.   These subsurface disposal systems dispersed liquid effluent
into  the ground by filtration through a sand  and gravel leach field.  According  to Valley/GRC, more than
20 gallons of waste cutting oil  containing TCE and other hazardous  substances were released each month, on
the ground at  the south end of the  building between 1964 and  1972.  Also,  at least four 55-gallon drums of
the same material were  used  as  a  defoliant  on the eastern  side of the building. Between 1979  and 1984,
effluent  from  an acid  bath  finishing  process  was discharged  to  an  underground  leach  field, and
TCE-contaminated oil was released on the soil under  a loading dock and into a floor drain.  In 1973, 500
gallons of raw TCE was  released from an underground storage tank into the soil, and additional  waste oils
and solvents were dumped on  the ground.  A site investigation  in 1983 revealed high levels of TCE, arsenic,
lead,  and  copper in  the underground disposal systems.   Additional  sample  analysis  has detected soil
contaminated with VOCs from the surface to  a depth of  15 feet in various locations  onsite.  Analysis  of
surface water and sediments from Mill Pond, downstream  of the Valley site, as well as ground water from
monitoring wells in the site  area, also detected VOC  contamination.  Based on  the concentration  of VOCs
detected  in the subsurface soil and ground water and historical site use information, both media are believed
to be contributing to ground  water and surface water contamination in the Valley site area and the Mill
Pond/Johnson Creek watershed and aquifer.  The primary contaminants of concern affecting soil, sediments,
ground water, and surface water  are VOCs including TCE, PCE, toluene, and metals including arsenic and
lead.

      The selected remedial action for the Valley site operable unit includes:  in situ vacuum extraction of
approximately 20,000 yd  of unsaturated soil followed by  activated carbon treatment of the extracted VOCs;
onsite ground water pump and treatment by carbon adsorption  and  aeration, with recharge to the  aquifer of
a portion of the  treated ground  water upgradient of the site to accelerate removal of saturated  zone soil
contamination,  and discharge of the remainder of  the treated ground water to the aquifer downgradient of
the site,  and treatment of  air emissions from  the aeration process by carbon adsorption; ground  water
monitoring; and sealing or disconnecting all drains and lines to the acid bath finishing process disposal system.
Incidental treatment of inorganic  compounds  and other contaminants will be provided as necessary in order
to operate the VOC contaminant  treatment system efficiently and to meet  applicable discharge permit
requirements.  The estimated present worth cost of this remedial action is $4,165,000, with a 10-year present
worth O&M cost of $2,677,000.
                                                B-9

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                    Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  GROVELAND WELLS, MA
                                      First Remedial Action
                                       September 30, 1988
                                          (continued)


PERFORMANCE STANDARDS OR GOALS:  Ground water cleanup levels for VOCs are based on MCLs
or an excess cancer risk level of 10~6.  Individual goals include PCE 5.0 ug/1 (MCL), TCE 5.0 ug/1 (MCL)
and toluene 2,000 ug/1.  Inorganic contaminant cleanup levels are based on State of Massachusetts Ground
Water Quality Standards and ground water discharge permit requirements.  Individual goals include arsenic
50 ug/1 and lead 50 ug/1.  Individual soil cleanup goals for VOCs are based on achieving the  target ground
water levels and include TCE 6.3 ug/kg and PCE 18.2 ug/kg.

INSTITUTIONAL CONTROLS:  Not applicable.
                                             B-10

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     IRON HORSE PARK, MA
                                        First Remedial Action
                                         September 15, 1988
ROD ABSTRACT
      The Iron Horse Park site is a 552-acre industrial complex and railyard located in North Billerica,
Massachusetts.   The  site includes  manufacturing and railyard maintenance facilities, open  storage  areas,
landfills,  and wastewater lagoons.  A long history of activities at the site has resulted  in contamination of
soil, ground water, and surface water.  In August  1984, EPA, under its removal authority, covered an  onsite
asbestos landfill located northwest and adjacent to the lagoons area.  In September 1984, the site was placed
on the NPL. In 1985, EPA began evaluations of  the site and concluded that the size and complexity  of the
site, as well as the discreet nature of the contamination, necessitated dividing the site into several separate
problem  areas.  This ROD addresses the cleanup of the  Boston and Maine Wastewater Lagoons (B&M
Lagoons)  and surrounding area, which are operated by Boston & Maine (B&M) Corporation.  The  B&M
Lagoons  are a series of lagoons located within a 150-acre parcel of land leased from the Massachusetts Bay
Transportation Authority, which uses most of the  land to operate a passenger rail service.  The lagoons have
been receiving untreated industrial and sanitary wastewater from the manufacturing and railyard maintenance
facilities since 1915. The lagoon area consists of the North and South lagoons, currently receiving wastewater,
an overflow lagoon, one inactive  lagoon used until 1954,  and an empty lagoon that was never  used.  The
lagoons contain approximately 7,800 yd of soil and sludge  contaminated primarily with VOCs, low levels of
PAHs, and metals. In addition, approximately 20,000 yd of soil and sludge dredged from the lagoon bottoms
and disposed in piles  along the lagoon banks are  contaminated with low levels of organics and metals. The
piles of dredged  material and the  sludge in the lagoons are not considered to contribute significantly to
ground water contamination.   This conclusion is based,on the results of the TCLP test  which indicates that
these materials do not leach contaminants in significant concentrations. Additionally, the contaminants found
in these materials are generally not  found in  the ground water. B&M has been ordered to stop  discharging
wastewater to the B&M Lagoons by the end of 1988 and  plans to tie-in to the town  of Billerica's  sewer
system.   Subsequent RODs will address  other portions of the site including a landfill and site-wide ground
water.   The primary  contaminants  of concern affecting the  soil,  sludge,  and debris are VOCs, organics
including PAHs, and  metals including arsenic and lead.

      The  selected   remedial action  for  this site includes:   excavation and onsite  biodegradation  of
contaminated soil and sludge  with residual disposal to the  lagoon  area, followed by covering with a clean
soil cover and revegetation; and decontamination of the lagoon system piping and pumps.  The estimated
capital cost  for this remedial action is $2,273,000  with present worth O&M of $47,000.

PERFORMANCE STANDARDS OR GOALS:  Treatment  of soil  and sludge will attain a  less than 10"6
excess cancer risk for industrial use of the area,  and a less than  10~5 excess cancer risk for  residential use
of the area.  Treatment should reduce contaminant concentration in wastes by 70 to 80 percent, and will meet
the  state pathogen reduction requirements for sludge.  Individual cleanup levels were not specified.

INSTITUTIONAL CONTROLS:   Deed restrictions  will be  implemented to restrict land use.
                                               B-ll

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                           KEEFE ENVIRONMENTAL SERVICES,  NH
                                  Second Remedial Action - Final
                                          March 21, 1988
ROD ABSTRACT
      The Keefe  Environmental Services (KES) site  is located in a  semi-rural area in Epping,  New
Hampshire.  Surface water from sections  of this site flows toward a wetland area  to the immediate south.
Considerable filling and excavation have occurred at the site using the materials for site fill, road construction,
surface leveling, and dike construction purposes.  In May 1978, Mr. Paul Keefe constructed a chemical waste
storage facility by establishing drum storage areas, large storage tanks, equipment shelters and a bulking area.
A 700,000 gallon capacity, synthetically lined, waste lagoon was  also installed.  During April 1979, the  New
Hampshire Bureau of Solid Waste Management (NHBSWM) and the Division of Public Health Services
(DPHS) ordered KES to clean up a number of leaking  storage tanks, ruptured drums, improperly dumped
latex waste  and  contaminated  soils.  At  this time,  a series of complaints  were made by local residents
concerning strong odors attributed to the site. These complaints resulted in legal action against KES. During
September 1979, a  surface water and  ground water  sampling  program identified seven  chlorinated
hydrocarbons in  the ground water wells.   This resulted in the issuance of a  second cleanup order focusing
on the removal of  all leaking drums, spills and contaminated soil, daily inspection  of drums for leaks, and
reduction in total number of drums stored onsite. Beginning in  November 1979, drinking water wells of the
twelve  surrounding residences were sampled by the  New Hampshire Water  Supply  and Pollution  Control
Commission (NHWSPCC) for chemical compounds and biological parameters.  The sampling indicated the
presence of several VOCs in some wells.  Removal actions initiated between June 1981 and November 1982,
and then again in March 1983, removed 2,029 fifty-five gallon  drums, 84 thirty  gallon  drums, 47 cauldrons and
trays, 51 carboys, 1,630 five gallon  pails, 124 empty drums, and 10 fiber  and 155 miscellaneous containers.
In addition, approximately 4,100 five gallon  drums, 4  five-thousand gallon, and 4  ten-thousand gallon
above-ground tanks were removed from the site.  A first operable  unit  ROD, signed in  November 1983,
approved the removal of contents from the lagoon, lagoon liner, and adjacent contaminated soil.  This second
operable unit addresses soil and ground water contaminated  with  VOCs.

      The selected remedial action for this site includes:  in-situ  treatment of soil  using vacuum extraction
with discharge to the atmosphere and ground water  pump and  treatment using air stripping, filtration, and
carbon adsorption  with discharge to a ground water recharge area adjacent  to the wetland along the site
border.   The  estimated capital cost for  this remedial  action is  $1,942,300 with present  worth O&M  of
$4,157,700.

PERFORMANCE STANDARDS OR GOALS:  Ground water cleanup will meet a 10"5 cumulative excess
risk. Individual ground water cleanup goals include:  benzene 5 ug/1 (MCL), trichloroethylene 5 ug/1 (MCL),
tetrachloroethylene   5 ug/1 (based on TCE level), 1,2-dichloroethane 5 ug/1 (MCL), and 1,1-dichloroethylene
7 ug/1 (MCL). Cumulative soil cleanup goals will attain a 5.7 X  10"  excess cancer risk level.  Individual soil
levels include:  benzene 20.8 ug/kg, PCE  91.0 ug/kg, TCE 31.5  ug/kg,  1,2-dichloroethane 3.5  ug/kg, and
1,1-dichloroethylene 22.8 ug/kg.

INSTITUTIONAL  CONTROLS:  Not applicable.
                                              B-12

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                            LANDFILL & RESOURCE RECOVERY, RI
                                    First  Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The Landfill & Resource Recovery (L&RR) site  is located in North Smithfield, Rhode Island, and
consists of a 28-acre landfill and a sand and gravel pit.  Several unnamed streams lie to the south and east
of the site and flow through wetlands located adjacent to the site area. Several homes near the site use
ground  water  for  drinking, and the  Statesville reservoir, used  for recreational activities, is located
approximately 0.5 miles from the site. The L&RR site is a former sand and gravel pit that began accepting
domestic,  commercial, and industrial  wastes in 1927.  Site owners claim the  hazardous materials were mixed
in with  municipal refuse and deposited in the  north-central area of  the  site, but other reports  indicate
hazardous waste was spread over the entire site area.  When hazardous waste disposal ceased in 1979, the
owners placed a PVC cover  over the north-central area to prevent stormwater infiltration.  Commercial and
domestic wastes were disposed of on top of and around the area  in subsequent years.  In 1983, the Rhode
Island Department of Health installed monitoring wells onsite to  ensure compliance with State regulations,
and based on sampling results, ordered  the site closed.  Upon final closure in 1985, the owners covered 80
percent  of the landfill area with one foot of sand, another synthetic cover and topsoil.   Eighteen gas  vents
were Installed to vent gases underlying the synthetic cover. The sand used as final cover has eroded into the
adjacent wetlands, but sampling indicated no contamination was present. Low levels of VOCs and metals
including lead, cadmium, and arsenic  were discovered in downgradient ground water samples, but levels  were
sporatic and all were below MCLs. This remedial action will upgrade the existing landfill enclosure to protect
ground water and wetlands, implement  wetlands recovery operations, and  collect and  treat landfill gas to
reduce risks to public health  from  inhalation. Primary contaminants of concern affecting the air are hydrogen
sulfide and methane gases contaminated with VOCs including benzene, toluene, PCE, and TCE.

      The selected remedial action for  this site  includes:  access restrictions; stabilization of the steep side
slopes of the landfill and installation of a RCRA  cap over the entire landfill with revegetation; collection and
thermal destruction  of underlying gases, the method of thermal destruction to be determined in design;
excavation of eroded landfill sand from the wetlands with replacement onsite and vegetation  of excavated
wetland areas;  and ground  water and air monitoring.  The estimated present worth cost of the  selected
remedy is between $5,674,000 and $6,790,000, depending on the particular method of slope remediation and
thermal destruction chosen.  O&M costs were not provided.

PERFORMANCE STANDARDS OR GOALS:  Thermal destruction  of landfill  gases will meet the Rhode
Island Air Toxic Regulations at the site  boundary.

INSTITUTIONAL CONTROLS:   Not applicable.
                                              B-13

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                       LAUREL PARK, CT
                                    First Remedial Action - Final
                                           June 30, 1988
ROD ABSTRACT
      The Laurel Park site is located in the Town of Naugatuck, New Haven  County,  Connecticut.  The
landfill, occupying about 19-acres of the 35-acre site, lies entirely within the drainage basin of the Naugatuck
River.  Additionally, the landfill is located  on a hill in close proximity to fractured bedrock and bedrock
aquifer.  It is assumed that waste disposal actions began in the late 1940s.  It was common practice to burn
some of the waste brought to the site.  Operational problems at the landfill were reported in the early 1960s.
Complaints included chemical spills on roads leading to the landfill, large quantities of black acid smoke,
odors, and blowing litter. In 1961, a lawsuit was filed and, in 1964, the owner was ordered to cease burning
certain waste types.  Between 1965 and 1966, the Connecticut State Department of Health investigated reports
of contaminated surface water.  Construction of a leachate collection system was completed  in 1984.  The
operators  of Laurel Park were ordered in January 1981  to stop landfilling in an unapproved excavation area.
By April 1987, the landfill ceased receiving  wastes.   The primary contaminants of concern affecting ground
water, soil, surface water, and sediments include:  VOCs, organics, and  metals.

      The selected remedial action for this site includes: installation of  a RCRA cap over all waste disposal
areas; rehabilitation of existing leachate collection system, supplemented by a shallow ground water extraction
system consisting of a French drain and/or ground water extraction wells, with discharge and offsite treatment
at the Naugatuck Water Pollution Control Facility (NWPCF); and monitoring of all media. The estimated
present  worth cost  for this remedial action is $21,706,300 without  pretreatment,  or  $23,078,200 including
pretreatment, if necessary.

PERFORMANCE STANDARDS OR GOALS: Ground water and leachate will be extracted to meet the
RCRA Ground Water Protection Standard (GWPS)  at the point of compliance, which is the vertical surface
located at the hydraulically downgradient limit of the waste management area.  Currently, the GWPS is set
at the MCLs, ACLs, or background.  Specific individual cleanup levels were not  specified.

INSTITUTIONAL CONTROLS:  Institutional controls have  been recommended to prevent the  bedrock
aquifer in the site vicinity from  being used as a source  of water  for any purpose.
                                              B-14

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                OLD SPRINGFIELD LANDFILL, VT
                                       First Remedial Action
                                         September 22, 1988
ROD ABSTRACT
      The Old Springfield Landfill site is located approximately one  mile southwest of the city center in
Springfield, Windsor County, Vermont.  The land use within a one mile radius of the 27-acre site is primarily
low density residential housing, light agriculture, undeveloped forest land and commercial development.  The
landfill was operated by the Town of Springfield between 1947 and  1968 for the disposal of municipal solid
waste and hazardous industrial liquid and semi-liquid waste. The site is currently owned by Springfield Mobile
Home Estates, which operates a  trailer park currently consisting of 38  mobile homes.  Approximately 60
people reside in the Springfield Mobile Estates trailer park, built on top  of the landfill.  The site first came
to the attention of the Vermont Department of Health because of  a complaint by a nearby resident of
foul-smelling water. Investigation of the site found VOC contamination in a spring and in a residential  well
near the mobile home park. EPA began investigations at the site in  1976.  Four areas of contamination have
been identified at the site where industrial waste was either disposed  of in discrete trenches or mixed  with
the municipal waste. This remedial action addresses landfill seepage and ground water contamination.  The
remedial  action is  designed  for  management  of  contaminant migration and study of final remediation
alternatives.  The primary contaminants of concern affecting the  ground water, surface water, soil,  and
sediments are  VOCs including benzene, PCE, TCE, toluene, and other organics including PCBs and PAHs.

      The selected remedial  action for this site includes:  construction of an  underground collection system
to collect  leachate; installation of wells for extraction of contaminated  ground water; onsite treatment of the
collected leachate and extracted ground water, or discharge to the Publicly Owned Treatment Works (POTW)
for treatment; institutional controls to restrict  the use  of ground water that exceeds MCLs; multimedia
monitoring; and additional  studies to determine the feasibility of isolating waste materials from the ground
water (e.g., french drain, slurry wall, or waste removal).  The estimated present worth cost for this remedial
action is $5,374,000  with annual O&M costs  of $173,000.

PERFORMANCE STANDARDS OR GOALS: Cleanup goals for ground water and leachate will attain MCLs
and include benzene 5 ug/1,  1,1-dichloroethene 7 ug/1, trichloroethene 5 ug/1, and vinyl chloride 2 ug/1.

INSTITUTIONAL CONTROLS:   Institutional controls will be  implemented and enforced to restrict the use
of ground water where it may exceed MCLs.
                                              B-15

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    ROSE DISPOSAL PIT, MA
                                    First Remedial Action - Final
                                         September 23, 1988
ROD ABSTRACT
      The Rose  Disposal Pit site occupies 1.5 acres in the northern  section of a 14-acre  residential lot
located in Lanesborough, Massachusetts, approximately 4 miles north of Pittsfield.  The property encompassing
the site is bounded on the north, northeast, and west by forests, on the east and southeast by cropland and
pasture, and on the southwest by a residential area.  There is a small wetland  west of the disposal area and
a larger forested wetland to the southeast of the property. A small man-made pond is located approximately
200 feet south of the disposal area.   During the  1950s and possibly later, the  General Electric Company
disposed of waste oils and solvents in a trench on the site, now referred to as the disposal area.   Field
investigations conducted between  1981  and 1986  revealed  high  concentrations of PCBs in surface and
subsurface  soils and indicated the presence of VOCs in ground water.   The volume of contaminated  soil to
be remediated is approximately 15,000 yd . The primary contaminants of concern affecting the soil, sediments,
ground water and surface water are VOCs including PCE, TCE, toluene, xylenes and other organics including
PCBs.

      The selected remedial action for this site includes: excavation and onsite incineration of approximately
15,000 yd3  of contaminated soil and sediment with residue disposal onsite; ground water pump and treatment
onsite using air stripping and carbon adsorption with discharge to the aquifer;  installation of a bedrock well
to prohibit ground water migration; treatment of pond sediments and surface water and subsequent restoration
of the  onsite pond to its original wetlands character; implementation  of institutional controls; and ground
water monitoring.  The estimated present worth cost for this remedial action is $6,450,000 with estimated
present worth O&M  of $5,790,000.

PERFORMANCE STANDARDS  OR GOALS:  PCB-contaminated soil above 13 mg/kg (based on 10"5 risk
level) will be excavated and treated to a PCB concentration of less than 2 mg/kg.  Treated ground water
will achieve MCLs, if available, or MCLGs, Lifetime Health Advisory (LHA) or a 10"b cancer risk level.
Individual ground water cleanup goals include PCE 1 ug/1 (10" risk level), benzene (MCL), and TCE (MCL).

INSTITUTIONAL CONTROLS:  Institutional controls will be implemented to  prevent ground water use and
excavation  within  the disposal area.
                                               B-16

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                    YAWORSKI LAGOON, CT
                                    First Remedial Action -  Final
                                         September 29, 1988
ROD ABSTRACT
      The Yaworski Lagoon site is a dewatered and backfilled lagoon, approximately 700 feet long and 300
feet wide and surrounded by an earthen dike. It is located on an approximately 100-acre section of land in
Canterbury Township, Windham County, Connecticut, on the floodplain of and bordered on the north, south
and west by the Quinebaug River.  The area surrounding the site includes agricultural  land to the east and
south.  Leachate enters the ground water from below the lagoon; seepage from the lagoon dikes and surface
runoff from the site flow to adjacent wetlands. Approximately 2000 feet southeast of the site is an operating
solid waste landfill  owned by James Yaworski, the same person  who operated the lagoon.  The  landfill
contributes some contamination to ground water, but EPA monitored the site in 1988 and determined the
contamination to be much less than  from the lagoon.  Between 1950 and  1973, sludge materials and drums
of industrial waste including solvents, paint, textile dyes, acids,  resins, and  other debris,  about 50,000 barrels
of waste material altogether, were deposited in the lagoon.  The lagoon currently contains approximately
65,000 cubic yards of contaminated sludge covered by about 60,000 cubic yards of contaminated debris. The
sludge is a mixture of water, dirt, VOCs, and other organic compounds at  concentrations above 10,000 ppm.
Metals are at concentrations above 1000 ppm. Monitoring wells were installed at  the site in 1976 and ground
water contamination was detected. In 1982, following an investigation of the site,  CT DEP ordered Yaworski
to close the lagoon.  The primary contaminants of concern affecting the ground water, soil and sediments are
VOCs including benzene, toluene and xylenes, organics including PAHs and metals including chromium and
lead.

      The selected remedial action for this site includes:  installation of a RCRA cap; improvement of dike
around  the lagoon to ensure protection from floods; establishment of a ground water protection standard
(ACL);  and monitoring of ground water for 30 years.  A ground water treatment method will be established
as part  of a corrective action program if, after  implementation of the source  control remedy, ground water
contamination remains above ACLs.  The estimated  capital cost  of this remedial  action is $1,673,000 with
present  worth O&M of $716,600.

PERFORMANCE STANDARDS OR GOALS: Ground water ACLs will be established as part of the selected
remedy.  Individual ACLs were not specified.

INSTITUTIONAL CONTROLS:  Restrictions will be implemented to restrict ground water  use  onsite and
within 1500 feet offsite.
                                              B-17

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                 AMERICAN THERMOSTAT, NY
                                       First Remedial Action
                                          January 7, 1988
ROD ABSTRACT
      The American Thermostat Corporation (ATC) site, occupying approximately eight acres, is located
in South Cairo, New York. Private homes are near the site on its eastern and western boundaries.  Former
plant operations involving  the assembly of thermostats for small appliances were carried out in one existing
large building.  From the mid 1950s through at least 1981, waste containing TCE and PCE sludges were
poured down drains which were  connected to an abandoned septic system and dumped outside onto plant
grounds. The drains were connected to the abandoned septic system. In March 1981, two ATC employees
were observed dumping solvents  on plant  property.  This triggered investigations into the company's waste
handling practices by the New York State Department of Environmental Conservation (NYSDEC) and the
New York State Attorney General's office.  Subsequently, water samples collected in five privately-owned wells
in the ATC vicinity revealed the presence of high levels of TCE and PCE. As a result, ATC began supplying
bottled water to local residents in April 1981.  By late 1982, ATC had installed carbon filters on its own well
and the affected residential wells. Pursuant to a 1983 Consent Order, ATC and AMRO Realty Corporation
(AMRO), the owners of the property, agreed to clean up the site and its surroundings; supply bottled water
for  cooking and drinking  purposes; and  install,  monitor, and maintain  carbon filter systems for  the  five
affected homes.  ATC and AMRO did not fully comply with  the Consent Order and  did  not remedy the
contamination at the site.  In June 1983, a new onsite 4,500-gallon septic system was installed and, in
September 1983, ATC provided  carbon filtration for septic system discharges to lower PCE levels.  ATC
ceased operations in May 1985 and filed involuntary bankruptcy.  EPA has been sampling  area wells  and
maintaining previously installed carbon filtration units. In addition, EPA installed two new carbon filtration
units on contaminated private wells;  installed two air stripping system on a highly contaminated well;  and
drilled a new well attempting to locate a clean water supply.  The primary contaminants of concern affecting
the ground water are VOCs including PCE and TCE.

      The selected remedial action for this site includes:  provision of an alternate water  supply through
extension  of  the existing Catskill Water District pipeline from Sandy Plains Road or from Rudolph Weir
Road to the affected and potentially affected area.  The exact  route of the pipeline will be  determined during
design.  The estimated capital cost for this remedial action ranges from $2,270,000 to $2,380,000 with annual
O&M of $100,000 to $110,000, pending the pipeline route decision.

PERFORMANCE STANDARDS  OR GOALS:  This first operable unit will meet the MCLs for TCE 0.005
mg/1, 1,1-dichloroethylene 0.007  ug/1,  and 1,1,1-trichloroethane 0.200 mg/1, and  the Water  Quality Criteria
chronic level  for PCE of 0.800 mg/1.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-18

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                       ASBESTOS DUMP, NJ
                                        First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The Asbestos Dump site is an 11-acre commercial property, formerly an  asbestos processing plant,
in Millington, New Jersey.  It  is bounded by the Passaic River, the Millington Train Station, commercial
properties, and private residences.  Part of the  site lies within the flood plain of the Passaic River which
serves as  a public water supply source for 74,000 people.  Approximately 200 individuals are employed by
21 businesses operating on the active portion of the site.  Asbestos,  Limited, engaged in the fiberization and
sale of asbestos at the  site from 1927 until 1946.  From  1946 until 1953, the plant  was owned  by Bernard E.
Smith and operated under the name of Smith Asbestos, Inc., a manufacturer of asbestos roofing and siding.
During these years waste water  from the manufacturing process was  impounded on the site to  permit settling
of asbestos fibers suspended in the water.  Periodically, the sediment was removed, disposed of onsite and
covered with dirt.  In May 1953, the property was acquired by National Gypsum, which manufactured cement
asbestos siding and roofing sheets at the plant until 1975.  Most of the waste was recaptured and recycled
during this period, although broken siding and asbestos fibers  were dumped  on a five-acre area on the
property.  From 1959 until 1972, National Gypsum used phenylmercuric acetate (PMA) as a fungicide to coat
the asbestos shingles.   Waste generated by the cleaning of coating equipment was disposed of in  small pits
onsite.  In May 1975, National  Gypsum closed the Millington plant. The total  asbestos waste at the site is
estimated  to be 90,000 cubic yards. The primary contaminant of concern affecting ground water and soil is
asbestos.

      The selected remedial action for this site includes:  installation of a two-foot soil cover on areas of
exposed or  minimally  covered  asbestos,  construction of slope protection/stabilization measures  along the
asbestos mound embankment, and surface run-off diversion channels on top of asbestos  mound;  long-term
monitoring including offsite ground water monitoring;  access restrictions; institutional controls to restrict
onsite ground water use and limit development on the  asbestos fill area; and performance  of treatability
studies to  evaluate technologies that may permanently remediate asbestos.  The estimated present worth cost
for this  remedial action is $1,145,000 with annual O&M of $56,000  to $161,000.

PERFORMANCE  STANDARDS  OR GOALS:   The selected remedy, covering the asbestos contaminated
areas with two feet of soil, will  comply with the National Emissions  Standards for Hazardous  Air Pollutants
(NESHAPs) requirements of the Clean Air Act.

INSTITUTIONAL CONTROLS:  Institutional controls will be implemented to prevent onsite ground water
use and development on the asbestos fill areas.
                                               B-19

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                              BEACHWOOD/BERKELEY WELL, NJ
                                   First Remedial Action - Final
                                           June 30, 1988
ROD ABSTRACT
      The Beachwood/Berkeley Well site, encompasses Beachwood  Borough and Berkeley Township  in
central-east Ocean City, NJ.  The total  population of the  two municipalities is  approximately 23,000.   In
response to a public complaint  of possible  aluminum  contamination of drinking water,  the New Jersey
Department of Environmental Protection (NJDEP) sampled four potable wells and discovered the presence
of lead in excess of the Federal Interim Primary Drinking Water Standard. Subsequent sampling confirmed
the  presence of  lead at approximately four times the standard.  The Ocean County Health Department
collected additional samples in the two municipalities.  Results of analyses indicated that 15 percent of the
total wells sampled in the Borough and three percent of  the  residential wells  sampled in  the  Township
exceeded the regulatory standard for lead  in  drinking water; however, there was no  distinct geographical
pattern to the occurrence of the lead contamination.  By order of the NJDEP, an alternate supply of water
was provided to  the affected residents.  After  extensive  investigation of lead  levels in residential tap water,
surface water, ground water, sediments and soils and lead concentrations  in and  dissolution from plumbing
systems, it was concluded that elevated concentrations of lead in drinking water were not caused by man-made
or industrial sources.  Rather, the sources of lead include a minor contribution  from native area ground water,
lead packers used in well construction and dissolution of lead from lead-bearing materials of home plumbing
systems, particularly lead/tin solder.

      Remediation under the  Superfund program of the documented existence  of lead in drinking water
resulting from dissolution from residential plumbing systems is precluded by law.   The State of New Jersey
is proceeding independently of Federal Superfund financing to address the problems posed by the presence
of lead in drinking water.

PERFORMANCE  STANDARDS  OR  GOALS:   Remediation involves  the interim remedy waiver for
contaminant-specific ARARs; however, ground water extraction and discharge will meet MCLs.   Individual
MCL  goals were not specified.

INSTITUTIONAL CONTROLS:  Not applicable.
                                              B-20

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  BREWSTER WELL FIELD, NY
                                   Second Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The Brewster Well  Field consists of two  municipal well fields,  No. 1 and  No. 2, located on  the
northern bank of the East Branch Croton  River, 3/4 of a mile east of the Village of Brewster, Town of
Southeast in Putnam, New York.  The 18 shallow wells in the field are a source of water for the municipal
water system that serves over 2100 residents hi the Village of Brewster and the Town  of Southeast, as well
as a number of businesses and a railyard.  Additional receptors of the ground water from this aquifer include
downstream users of the East Branch Croton  River,  which contributes  to  the  Croton Falls Reservoir
approximately 3.5 miles downstream.  Also, two  reservoirs exist upstream to the east  and northeast within
3000 feet of the site, which are part of New York City's Croton watershed reservoir system. Land use to the
north and west  is  predominantly  residential,  and to  the south  commercial  and light industrial.   VOC
contamination was detected in the Brewster Well Field in 1978 and alternate water sources were subsequently
added. Investigations identified the source of contamination as a drywell adjacent to the Alben Cleaners south
of the site, where dry cleaning wastes were  disposed of via a floor drain until 1983.  Approximately 100  yd
of material including drywell sludges, sediments and soil have been contaminated with VOCs  at concentrations
up to 620,000 ppm.   In addition, a plume of ground water contaminated with VOCs at concentrations up to
6,000  ppb extends from the vicinity of the  cleaners north to the  Brewster Well Field.  Consequently,  the
Village of Brewster  and EPA have operated a full scale packed column spray aeration  system for treatment
of the entire village supply since 1984.   The first Record of Decision  (ROD) for  the  site was signed in
September 1986, and was aimed at controlling migration of contamination through the ground water.  The
ROD called for the design and construction of. a ground  water management system to extract, treat (by air
stripping via a packed tower) and reinject ground water to expedite the removal of VOCs.  This second ROD
is  designed to remediate the source  of contamination, namely the drywell.  The primary contaminants of
concern affecting  the soil, sediments,  sludge and ground water are VOCs including PCE and TCE.

      The selected  remedial action for this site includes: excavation and offsite incineration of approximately
100 yd3 of drywell sediments, sludge, and soil with greater than four ppm PCE followed  by offsite disposal;
and removal, decontamination and offsite disposal of the concrete drywell structure and debris. The estimated
capital cost for this  remedial action is $241,940.
PERFORMANCE STANDARDS OR GOALS:  Remediation of all soil, sediments, sludge and debris greater
than four ppm PCE will reduce health risks due i

INSTITUTIONAL CONTROLS: Not applicable.
than four ppm PCE will reduce health risks due to direct contact with contaminated site soils to 1 x 10 6
                                              B-21

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                      BURNT FLY BOG, NJ
                                      Second Remedial Action
                                        September 29,  1988
ROD ABSTRACT
      The Burnt Fly Bog site is located in Marlboro Township, Monmouth County, New Jersey.  The site
is  situated in a rural area with an auto salvage yard  and a few scattered residences  nearby.  The entire
Burnt Fly Bog encompasses about 1,700 acres.  This remedial action addresses the 10-acre area constituting
the Westerly Wetlands Operable Unit. The area is affected by contamination from the 10-acre parcel where
waste was originally deposited (Uplands Area  Operable Unit).  The site includes  both flood  plains and
wetlands.  Contamination has been detected in the surface water, surface soil, and the shallow subsurface soil
as a result of uncontrolled discharges and runoff from the Uplands Area waste sources.  The  Uplands Area
includes several abandoned oil storage and treatment  lagoons  containing  residual oil sludges and aqueous
wastes, contaminated waste piles and buried or exposed drummed wastes.  These are the result of activities
at the site from 1950 to 1965.  The site property is presently owned by Mr. Dominick Manzo, who operated
part of the property as a sanitary landfill from 1963 to 1969. The Uplands Area is currently being cleaned
up under  a Record  of Decision signed on November 16,  1983.  The volume of soil contaminated with PCBs
and  lead is estimated to be 76,400 yd  at  the site, with  an additional 5,600 yd  of contaminated  sediments
in an adjacent downstream area.  There is no evidence of PCB contamination in surface water. The primary
contaminants of concern affecting the surface water, soil and sediments are PCBs and lead.

      The selected remedial action  for this site  includes:  access  restrictions; excavation of contaminated
sediments from the downstream area with disposal at  an offsite RCRA  Subtitle C facility;  as  an interim
remedy, containment without capping contaminated soil  in the  Westerly Wetlands through installation of a
sedimentation basin and appropriate  diversion controls;  and performance of treatability studies on the most
promising innovative technology alternatives to provide  the final remedy.  A subsequent  ROD will address
this final remedy for the contaminated soil. The estimated present worth cost for this remedial action using
a 20-year  life estimate is $6,100,000 with annual O&M costs of $320,000.

PERFORMANCE STANDARDS OR GOALS:  The excavation  of the downstream area sediments meet the
State soil  cleanup criteria for PCBs 5 mg/kg and  lead 250 mg/kg.

INSTITUTIONAL CONTROLS:  Not applicable.
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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                      EWAN PROPERTY, NJ
                                       First Remedial Action
                                         September 29, 1988
ROD ABSTRACT
      The 43-acre Ewan Property  site  is located  in a predominantly agricultural and residential area of
Shamong Township, Burlington County,  New Jersey.  Private residences are provided domestic water from
wells as close as one mile downgradient from the site, drawing from an aquifer that extends from beneath
the site.  The site is broken into two study areas, Area A and Area B.  Area A, consisting of nine acres,
is the area of concern.  Site investigations revealed that during the early to mid-1970s, at least  500 to 8,000
55-gallon drums containing hazardous industrial  wastes were disposed of in trenches in Area A, and the
trenches were subsequently backfilled with  soil.  Investigations also revealed  that many of the drums are
ruptured, corroded or leaking.  Soil and ground water samples indicate the presence of VOCs and metals.
It is estimated that Area A has 4,500 yd  of highly contaminated soil and waste material, and 29,500 yd  of
moderately contaminated soil.  Primary contaminants of concern affecting soil  and ground water are VOCs
such as benzene, TCE, PCE and xylenes, and metals including chromium and  lead.

      The selected remedial action for this  site includes: construction of decontamination, staging and waste
characterization areas; excavation, staging and characterization of waste materials with offsite incineration of
all appropriate wastes (approximately 4,500  yd of buried drums and heavily contaminated soil); temporary
onsite storage and  assessment of non-incinerable wastes to determine proper  disposal method; and monitoring
of air and ground water during remedial activities. The estimated present worth cost of the selected remedy
is $21,153,000 with estimated  annual O&M  costs  of $22,000.

PERFORMANCE  STANDARDS OR GOALS:  Will be determined  during the remediation of a subsequent
operable unit.

INSTITUTIONAL CONTROLS:  Not applicable.
                                              B-23

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    GE WIRING DEVICES, PR
                                    First Remedial Action - Final
                                         September 30, 1988
ROD ABSTRACT
      The GE Wiring Devices site is located in Juana Diaz, Puerto Rico.  The General Electric Company
(G.E.) owns and operates a five-acre wiring devices plant at this site, which assembled silent mercury switches
from 1957 until 1969. Approximately half a ton of mercury was discarded along with 4,000 yd of defective
switch parts and plastic scraps in an onsite waste-fill area about one acre in area and one to four feet deep.
Several residences are located approximately 400 feet south of the waste-fill area,  which is surrounded by a
concrete  retaining wall and a fence.   Ground water in the area is used as a  source of drinking water with
a public supply well  located approximately 1,500 feet west of the waste-fill area.  In addition, ground water
flows  to the west toward the San Jacaquas River. About 500,000 gallons of perched water has accumulated
within the waste-fill area as a result of precipitation/recharge.  Evidence indicates  that contamination of the
water table is occurring due to the migration of perch water through  the clay layer that exists beneath the
waste-fill area. Approximately 1,500 yd  of near-surface soil south and downgradient of the waste-fill area
has been contaminated by mercury primarily as a result of previous surface runoff  from the plant  area. The
primary contaminant of concern affecting the ground water,  soil, and debris is mercury.

      The selected remedial action for this site includes: onsite hydrometallurgical  treatment of the waste-fill
materials, perched water and  contaminated near-surface soil with disposal  of the treatment residue in the
former waste-fill  area, followed by covering with a clean soil cover,  and onsite  treatment of the  process
leaching agent with discharge to a POTW; additional investigation of the ground water to determine the extent
of contamination; and limited ground  water monitoring, provided there is no  need  for  ground water
remediation.   The estimated  capital  cost for this remedial action is $1,912,870. There  are no O&M costs
associated with this remedy.

PERFORMANCE STANDARDS  OR GOALS:   Soil,  perched  water, and  debris  will  be  treated  to  a
health-based  cleanup level of 16  ppm if further air sampling verifies levels exceeding the EPA National
Emission Standard for a Hazardous Pollutant (NESHAP), or 21 ppb, based on risk due to ingestion, if there
are no levels exceeding NESHAP.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-24

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                      Progress Toward Implementing Superfund:  Fiscal Year 1988
                                      KIN-BUC LANDFILL, NJ
                                         First Remedial Action
                                          September 30, 1988
ROD ABSTRACT
       The 220-acre Kin-Buc Landfill consists of a number of inactive industrial and municipal waste disposal
areas and is located in the Raritan River 100-year flood plain and within a coastal zone in Edison Township,
Middlesex County, New Jersey.  Bordering the site is an industrial park directly north, the Edison Township
Municipal Landfill 600 feet to the south, marshlands to the east, and the Raritan River bordering the west.
Land use within one mile of the  site includes residential, light industrial, and recreational areas.  Landfill
operations were conducted between 1947 and 1977. Details on the owners/operators of the site are unknown
prior to  1968, when Kin-Buc, Inc., leased  the  area from Inmar Associates.   According to  site records, an
estimated 70 million gallons of liquid wastes, including three million gallons of oily waste and over one million
tons of solid waste, were disposed of between 1973 and  1976  alone.  Examples of wastes received include
solvents,  waste oils, paint  sludges, cyanides, metal stripping wastes and  paint thinners.  The  Kin-Buc site
includes  three  major mounds:   Kin-Buc I  (30 acres),  Kin-Buc  II (12 acres), which  lies directly north of
Kin-Buc  I, and Mound B (9  acres) which lies  southwest  of Kin-Buc  I adjacent to the  Raritan  River.
Additionally,  three  pits of black oily leachate, Pits A,  B, and C, are located at the  southeastern edge of
Kin-Buc  I; there is  a refuse-filled low-lying area between Kin-Buc I and the Edison Landfill;  and an area of
impounded, tidally affected water, Pool C,  contaminated by Kin-Buc I is adjacent to the pits. Site activities
included  burying and compacting contained wastes in Kin-Buc II, and discharging hazardous liquid wastes into
bulldozed pits  at the top  of Kin-Buc I.  These practices resulted in numerous citizen complaints, caused
frequent  major onsite fires and a number of serious occupational injuries.  EPA began investigations in
January 1976 and detected the  discharge of hazardous substances from the facility.   In February  1980, EPA
began cleanup activities consisting of collection, treatment and disposal of Pool C leachate; a drum reduction
program; oily-phase leachate collection and onsite storage; and aqueous-phase leachate pretreatment, removal
and  offsite treatment.  In September  1980, Kin-Buc, Inc. was ordered to cap Kin-Buc I and II. This source
control ROD addresses remediation of the first of two operable units, which includes Kin-Buc I and II, Pool
C, and the low-lying area between Kin-Buc I  and Edison Landfill.  A subsequent ROD will address  offsite
migration controls.  The primary contaminants of concern affecting the ground water,  surface water, sediments,
soil and air are: VOCs including benzene and toluene, other organics including PAHs and PCBs, and metals
including arsenic and lead.

       The selected remedial action for this site  includes:  installation of a slurry wall surrounding the site;
RCRA capping over Kin-Buc II, a portion  of the low-lying area between Kin-Buc I  and the Edison Landfill,
and Pool C; maintenance and upgrading, if necessary, of the Kin-Buc I cap; collection of approximately three
million gallons of oily-phase leachate with offsite incineration and  residual  disposal;  collection  and  onsite
biological or carbon treatment of aqueous-phase leachate and contaminated ground water with discharge either
to surface water or  POTW, and dewatering of residual sludges and offsite  disposal; ground water monitoring;
and O&M. The estimated present worth cost for this remedial action is between $16,290,000 and $16,635,000
with annual O&M varying from $848,000 (year 1) to $405,000 (years 12-20).

PERFORMANCE  STANDARDS  OR GOALS:   Incineration  of oily-phase  leachate will  meet  six  nines
(99.9999%)  destruction and removal efficiency.  Aqueous-phase leachate and  contaminated ground water
discharge criteria will be  established  by NJDEP based on the results of treatability studies, but  will meet
NJAC water quality criteria and  wastewater  discharge  requirements.   Individual  cleanup  goals were not
specified.

INSTITUTIONAL CONTROLS:  Institutional  controls will be implemented  to restrict use  of the property
as necessary to prevent damage to the cover.
                                               B-25

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                      LIPARI LANDFILL, NJ
                                    Third Remedial Action - Final
                                            July 11, 1988
ROD ABSTRACT
      The Lipari Landfill site is a municipal and industrial waste landfill in Mantua Township, Gloucester
County, New Jersey.  The landfill  consists of an "onsite" and an "offsite" portion.  The  onsite portion is a
formerly active landfilling area that consists of a slurry wall/synthetic membrane containment system.  This
portion was addressed in a previous remedial action.  A separate previous remedial action focused on flushing
water-transportable contaminants from within the containment system.  This remedial action addresses the
offsite portion of the site which is the area outside of the encapsulation  system consisting of agricultural and
residential  areas that include several lakes, streams and parks.  The site is bordered by the Zee Orchard  on
the north and west, and a housing development on the northeast.  The site property was purchased by Mr.
Nicholas Lipari in 1958 and was used until 1971 for excavation  of sand and gravel and landfilling of municipal
and household wastes, liquid and semi-solid chemical wastes and other industrial wastes. Offsite investigations
indicate  that  lakes,  streams  and  marshland in the  area  surrounding the site have been impacted  by
contaminant migration from the landfill.  The primary contaminants of concern affecting the ground water,
surface water, sediments, soil and air are VOCs including benzene, toluene and xylene, and metals including
arsenic, chromium and lead.

      The selected remedial action  for  the offsite areas  includes: collection of the contaminated ground
water/leachate, followed by onsite treatment and discharge to  POTW; excavation of contaminated marsh
soil, and dredging and dewatering contaminated sediments, followed by thermal treatment and  offsite disposal
as  nonhazardous material; integration of offsite sampling with the onsite monitoring plan being developed
to monitor  the effectiveness of the onsite flushing action; and temporary remedial measures in the surrounding
marshland, if necessary, to  mitigate volatile emissions from leachate seepage areas.  The estimated present
worth cost  for this remedial action is  $21,000,000.  O&M costs were not provided.

PERFORMANCE STANDARDS OR GOALS: Soil cleanup will attain the New Jersey soil cleanup objectives
developed under the Environmental Cleanup and Responsibility Act (ECRA) and health or risk-based criteria.
Surface water cleanup will meet Federal and State Water Quality Criteria and surface  water standards.
Individual contaminant goals were not provided.

INSTITUTIONAL CONTROLS: Not applicable.
                                               B-26

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                         LOVE CANAL, NY
                                       Second Remedial Action
                                          October 26, 1987
ROD ABSTRACT
      The Love Canal site is located in the southeast corner of the city of Niagara Falls, New York, and
is approximately one-quarter mile north of the Niagara River.  The canal was one of two initial excavations
designed to provide inexpensive hydroelectric power for industrial development around the turn of the 20th
century.   Hooker  Chemicals and  Plastics Corporation (Hooker), now Occidental  Chemical  Corporation,
disposed of over 21,000 tons  of chemical wastes, including dioxin tainted trichlorophenols, into Love Canal
between 1942 and 1953.  In the mid to late 1970s, continued periods of high precipitation contributed to water
accumulation in the disposal area causing chemically-contaminated  leachate  to be carried to the surface and
into contact with residential basement foundations.  Also, dioxin and other contaminants migrated from Love
Canal to the  sewers  which have outfalls to nearby creeks.  The remedial program at  Love Canal has been
extensive and has occurred in two phases. Phase one consisted of measures aimed at site containment.  Phase
two has  been  directed at remediating contaminated  drainage tracts, including nearby creek  and sewer
sediments which are contaminated with 2,3,7,8-tetrachlorodibenzo-p-dioxin,  commonly  referred to as dioxin.
The 1985 remedial action called for the removal of contaminated sediments from  the creeks and sewers,
followed by interim storaee in an on-site containment facility.  This remedial action requires the removal  of
approximately 15,000 yd   and 1,000 yd  of creek  and sewer  sediments respectively,  as well  as associated
contaminated debris  from remediation.

      The selected  remedial action for  this site  includes:    construction of  an onsite  creek sediments
dewatering/containment facility (DCF) to include a separate  construction/demolition debris facility (CDF);
onsite thermal destruction of  the stored creek and sewer sediments and associated remedial waste stored  in
the DCF; thermal destruction of leachate treatment residuals and other dioxin contaminated material derived
from site remediations; onsite storage of uncontaminated debris in the CDF;  onsite disposal  of non-hazardous
thermal treatment  residuals in a manner that avoids disturbance of the existing cap; and scaling down of the
DCF to only  include the  construction/demolition debris material.  An estimated 25,000-35,000  yd of dioxin
contaminated material will require thermal destruction.  The estimated present worth  cost for  this remedial
action ranges from $26,400,000 to $31,400,000.

PERFORMANCE  STANDARDS OR GOALS: The Centers for Disease Control have generally applied a 1
ug/kg level of concern for dioxin in residential soils for  other areas  in the country. A technical review
determined that separation and  consolidation of the  dioxin-contaminated sediments above 1  ug/kg is not
implementable  and would lead to unacceptable project delays.  In addition, the community is opposed  to
any remedial alternative that  does  not  call for thermal destruction  of all the contaminated creek and sewer
sediments. As a result,  all materials (excluding 5,500 yd   of house debris) will be thermally  treated.  Six
nines (99.9999%) destruction and removal efficiency will be the performance  standard.  In addition, excavation
to approximately 18 inches will ensure  the elimination or reduction of risk.  (Creek sediment contamination
was detected  only  to a depth of 12 inches).

INSTITUTIONAL  CONTROLS:  Not applicable.
                                               B-27

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                            LOVE CANAL/93rd STREET SCHOOL, NY
                                       Third Remedial Action
                                         September 26, 1988
ROD ABSTRACT
      The Love Canal/93rd Street School site consists of approximately 19 acres and includes a school and
an adjacent vacant lot.  The site is located in Niagara Falls, New York, less than one mile northwest of Love
Canal and is within  the Love Canal Emergency Declaration Area. It is bordered by Bergholtz Creek to the
north and residential properties to the east,  west and south.  A  small area east of the school and adjacent
to Bergholtz Creek  is within a 100-year flood  plain.  Hooker Chemicals and Plastics Corporation disposed
of over 21,000 tons of various chemicals at the  Love Canal site from 1942 to 1953, when the site was deeded
over to the City of Niagara Falls Board of Education.  Sampling has revealed that approximately 6,000 yd
of soil are contaminated.  During the 1950s, home construction accelerated in the area.  Specifically, in 1950,
the 93rd Street School was built, and in 1954, the 99th Street School was built adjacent to the middle portion
of the Canal.  Prior to construction of the 93rd Street School, a drainage swale crossed the site.  Between
1938 and 1951, the swale was partially  filled with soil and rock debris, followed by sand and fly ash  materials.
In 1954, the site was graded to its present contours with approximately 3,000 yd  of fill material, including
fill from the 99th Street School.  The  fill material is reported to  contain fly ash and BHC  (pesticide) waste.
In  1980,  the  93rd  Street school  was closed due to public health concerns  related to  the potentially
contaminated fill material. The primary contaminants of concern affecting soil are  VOCs, including toluene
and xylenes, other organics including dioxins, PAHs and pesticides, and  metals including arsenic and lead.

      The selected  remedial action for this site includes:   excavation and solidification/stabilization of 7,500
yd  of soil; placement of solidified soil back in  excavated location; installation of a RCRA cap; ground water
monitoring; and implementation of treatability studies for solidification process.  The estimated capital cost
for this remedial action is $2,295,000 to $3,675,000 with estimated annual O&M of $121,000.

PERFORMANCE STANDARDS OR  GOALS:  This remedy will permanently immobilize soil  which poses
an unacceptable carcinogenic risk.  Specifically, all  excavated soil will be treated to meet the Land Disposal
Restrictions requirements for dioxin of less than  1  ug/1, as measured in the soil leachate by the TCLP test.

INSTITUTIONAL CONTROLS.   Not applicable.
                                               B-28

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                     Progress Toward Implementing Super-fund:  Fiscal Year 1988
                               LUDLOW SAND AND GRAVEL, NY
                                        First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The Ludlow Sand and Gravel site is located approximately six miles south of Utica, in the town of
Paris, Oneida County, New York.  The site consists of a gravel pit and landfill on a 130-acre tract of land,
owned and operated  by Mr. James Ludlow.  It is surrounded by rural residential and agricultural land and
includes a New York State designated wetland south and east of the fill area. The landfill, which is the focus
of this ROD, is in a ground water recharge zone to the principal aquifer along Sauquoit Creek.  Fill material
is in contact with  the ground water in some locations in the landfill.  Sauquoit Creek serves as a major
discharge  point for ground  water flowing from this  aquifer.   Various organizations and  individuals have
disposed of waste at the site since 1966.  This waste included domestic wastes, septic tank effluent, industrial
wastes such as dyes, waste oils and metallurgical cooling oils, and animal parts from a meat processing plant.
In late 1982, sampling revealed traces of PCB contamination in the leachate pools on the southern portion
of the property.  In July 1987, the District Court of Binghamton ordered Mr. Ludlow to  cease operations at
the site.   Mr.  Ludlow  complied with  the court order and closed the landfill by February 15, 1988.   The
primary contaminants of concern affecting soil, sediments and ground water are VOCs including benzene and
toluene  and organics including PCBs and phenols.

      The selected remedial action for this site includes:  consolidation and onsite disposal into the landfill
of approximately 10,000 yd   of contaminated soil and sediment adjacent to the landfill and installation of an
impermeable cover over the landfill; collection of leachate from seepage areas formed from the landfill and
dewatering of the landfill through use of a passive drain system or an active well system with onsite treatment
of the collected  leachate/ground  water  and  offsite  discharge  of the effluent,  or,  if dewatering is not
implemented, collection and  transportation of leachate offsite to  a permitted 'disposal facility; implementation
of upgradient ground water controls to lower and prevent the ground water table from coming in contact with
the waste  material; access restrictions; imposition of deed restrictions governing future use of the property;
and implementation of a long-term water quality monitoring program including both onsite and offsite ground
water, surface  water  and potable water supply wells.  A second remedial  action will address ground water
remediation, if necessary.  This remedial action  is a combination of three alternative remedies.  The present
worth cost is estimated to be between $3,727,200 and $14,548,900 with  an annual O&M between $58,900 and
$364,900.

PERFORMANCE  STANDARDS OR  GOALS:   Treated  effluent  for  discharge will meet substantive
requirements of the New York State Pollution Discharge Elimination System (6 NYCRR Parts 750-757 and
701.5), Technical  Operations Guidance Series (700 1.1.1), Ambient Water Quality Standards and Guidance
Values (April  1987),  all ground water and surface  water standards, and Freshwater Wetlands  Standards (6
NY CRR  Part 663-665).  PCBs will be cleaned up to a level of 10 ppm, as recommended by the TSCA PCB
Spill Cleanup Policy Final Rule (40 CFR Part 761).

INSTITUTIONAL CONTROLS: Deed restrictions will be implemented to control future use of the property.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   MARATHON BATTERY, NY
                                      Second Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The Marathon Battery Company (MBC) site, a former battery manufacturing plant, is located in the
Village of Cold Spring in Putnam, New York, approximately 40 miles north of New York City.  The area
surrounding the  site includes the Hudson River to the west, residential areas to the northwest, west,  and
southwest adjacent to the site, and wetlands including Foundry Cove, which is divided into East Foundry Cove
(EFC) and West Foundry Cove, to the south.  The site operated from 1952 to 1979 producing military  and
commercial batteries.  During this time the site changed ownership several times, finally operating as the
MBC from 1969 to 1979.  Before 1965, the plant's wastewater treatment system discharged into the Hudson
River at the Cold Spring pier via the Cold Spring sewer system,  except during periods of overload or system
shutdown during which time the process  effluent was  discharged directly into East  Foundry Cove Marsh
(EFCM) to the  southeast.  In  1965, however, the plant began  discharging all of the process effluent  into
EFCM after the  New York State Department of Health concluded that the industrial discharge could not be
managed by a new sewage treatment system proposed for the Village  of Cold Spring.  Between November
1972 and July 1973, a limited  cleanup was  conducted by MBC and other responsible parties, to remove
sediment from parts of Foundry Cove and surrounding areas  contaminated with cadmium and nickel in excess
of 900 mg/kg. Approximately 5,000 yd  of cadmium-contaminated sediments were dredged and subsequently
placed in a clay-lined underground vault on the plant property. However, studies conducted in Foundry Cove
between  1976 to 1980 continued to  detect cadmium and nickel  concentrations in excess of 900 mg/kg.  To
expedite  remediation, the site has been divided into three  separate geographic  areas  as follows:  Area I,
EFCM and Constitution Marsh southeast of the plant; Area II, the 11-acre former  battery plant grounds,
including the former battery manufacturing facility (presently used as a book repository),  a production well,
a 500,000 gallon water tower, building debris, a dredge spoils vault, a parking lot and nearby residential yards;
and Area III, EFC and the portion  of the Hudson River in  the  vicinity of the wastewater  discharge pipe on
Cold  Spring  pier.   A  ROD was signed  for Area I in September  1986 with cleanup activities to  include
dredging the EFCM and replacing  the sediments with clay and clean fill.  This ROD addresses  Area II
including localized soil  contamination primarily in the area around the building, under debris and around the
parking lot; dust inside  the building; and  the sludge spoils vault.  A  subsequent ROD will address Area III.
The primary contaminants of concern affecting the ground water, soil, debris and inside surfaces of a building
in Area II are:   VOCs including PCE and TCE, and metals including  cadmium and nickel.

      The selected remedial action for Area II at this site includes: decontamination of the inside  surfaces
and contents of the former battery facility to remove the heavy metal-contaminated dust; excavation of both
the cadmium-contaminated soil on the battery plant grounds and nearby residential  yards, and the dredge
spoils vault, followed by onsite  fixation of the excavated soil, dust and vault sediments and offsite disposal;
excavation of the VOC-contaminated soil hotspots followed by enhanced volatilization and replacement of the
clean residuals onsite; backfilling of the excavation areas with clean  fill; institutional controls; ground water
monitoring; and  evaluation  and performance of minor repairs,  if needed, to the inoperable sprinkler  and
heating systems inside the former battery facility.  The estimated present worth cost for this remedial action
is $10,010,000, with annual O&M of $775,000 (year 1) and $17,000 (years 2-30).

PERFORMANCE  STANDARDS OR GOALS:  Ground water cleanup goals will attain ACLs for indicator
compounds that  are below federal and state MCLs, if available, and include PCE 0  ug/1 and TCE 3 ug/1.
These goals will be attained in 3-10 years by  natural  attenuation.  There  are no ARARs promulgated for
heavy metals; however,  excavation of onsite and offsite cadmium-contaminated soils will attain a level of 20
mg/kg.

INSTITUTIONAL CONTROLS:  Institutional controls will  be implemented to restrict the development of
the aquifer for potable or municipal use.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                  MONTGOMERY TOWNSHIP HOUSING DEVELOPMENT, NJ
                                  Second Remedial Action - Final
                                           June 30, 1988
ROD ABSTRACT
      The Montgomery Township Housing Development (MTHD) site is located in Somerset County, New
Jersey. The Rocky Hill Municipal Wellfield (RHMW) Superfund site is also covered by this remedial action
because of its proximity to the MTHD and the similarity of the contaminants present. The 72-acre MTHD
site is a development  which includes  71  private homes, with  an additional six homes  affected  by the
contamination in the surrounding residential areas.  The RHMW consists of a two-acre tract of land in the
Borough of Rocky Hill, which supplies public water to the residents of Rocky Hill.  In 1978, a study of the
RHMW revealed TCE contamination, which led  to closure of one well and eventual installation of an air
stripping treatment unit  on the well in  1983.   Concern over the ground water contamination hi Rocky Hill
spurred the initial sampling of residential wells in MTHD from December 1979 to January 1980. In March
1981, Elizabethtown Water Company water lines were  installed hi MTHD, and residents were advised not to
use well water.  Twenty homes initially elected to connect to  the municipal  supply, and at the present time
38 residences have  hooked up.   In September  1987, an operable unit ROD was signed  by  EPA, which
provided for the supply of alternate water through the permanent hookup of all MTHD residences  and six
residences outside of MTHD to the available public water supply system.  Field investigations have identified
13 possible sources of contamination.  The nearby Princeton  Gamma Tech  property has been  identified as
a primary source of TCE contamination in the area.  The  primary contaminant of concern affecting the
ground water is TCE.

      The selected remedial action for this site includes:   ground water pumping and air stripping and
reinjecting the treated water back into the aquifer; connecting any remaining affected residences to the public
water supply, sealing the remaining private water supply and monitoring wells within the contaminant plume;
and implementing ground water monitoring.  Present  worth cost for this remedial action is $2,548,000 with
annual O&M costs of $94,000.

PERFORMANCE STANDARDS OR GOALS:  Ground  water cleanup will attain the State MCC for  TCE
1.0 ug/1.

INSTITUTIONAL CONTROLS:  Water well  use restrictions will be implemented.
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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                         NASCOLITE, NJ
                                       First Remedial Action
                                          March 31,  1988
ROD ABSTRACT
      The Nascolite site is located in the cities of Millville and Vineland, Cumberland County, New Jersey.
The 17.5-acre site is wooded and is in a residentially and industrially zoned area.  Several homes exist near
the site and rely on  potable wells for drinking water.  Between 1953 and 1980, the Nascolite Corporation
manufactured polymethyl methacrylate (MMA) sheets, commmonly known as plexiglass.  Waste residues from
the distillation of scrap acrylic, a manufacturing by-product, were stored in buried tanks onsite.  Perforations
in an excavated tank indicated the possibility of liquid waste leaking into the soils.  In 1981 and 1983, the New
Jersey Department of Environmental Protection (NJDEP) conducted onsite ground water sampling and  found
significant concentrations of VOCs.  NJDEP identified over 100 fifty-five gallon drums  and several buried
tanks on the site, most of which have been subsequently removed from the site by the property owner. The
remaining drums were removed by EPA.  The primary contaminants of concern affecting both ground  water
and soil include:  VOCs, base/neutrals, and MMA.

      The selected remedial action for this site includes:  ground water pump and treatment using a method
determined through pilot testing with reinjection into the aquifer; performance of additional soil and  onsite
building studies to determine appropriate future remedial measures; and provision of an alternate water supply
for potentially affected residents.  The estimated captial cost for this remedial action is $609,000 with annual
O&M of $266,000.

PERFORMANCE STANDARDS  OR GOALS:   The ROD did not state specific target concentrations for
contaminants; however,  it  indicated that cleanup goals  were developed using the  Clean Water Act, Safe
Drinking Water Act, Solid Waste Disposal Act, New Jersey Safe Drinking Water Act, and the Ground Water
Quality Criteria of the  New Jersey Administrative Code.  Additionally, for carcinogenic compounds without
cleanup  standards,  the 10    cancer  risk  cleanup  standard  will  be used.   A  goal of  50 ug/1  total
noncarcinogenic and  "non-A-280" compounds were selected for any other contaminants.

INSTITUTIONAL CONTROLS:  Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                       OLD BETHPAGE, NY
                                    First Remedial Action - Final
                                           March  17, 1988
ROD ABSTRACT
      The Old Bethpage landfill, covering approximately 65 acres, is located in Old Bethpage, Town of
Oyster Bay, Nassau  Country, New York.  Two public  drinking water wells, a residential  community, an
industrial park and a state park exist within the site's general vicinity. Beginning in 1958, the Town of Oyster
Bay operated the landfill as a municipal landfill.  In addition to municipal wastes and garbage, local industrial
wastes were disposed of on the landfill during the late 1960s and early 1970s.  The landfill ceased operations
in April 1986. A system  designed to collect, store, treat and dispose of leachate has been operating at the
site since  1983.  There are three  remedial actions  currently underway at  the site.  They include:  leachate
collection, methane gas collection and landfill capping.  The methane gas collection system was installed in
phases in  1982 at  the periphery of the site to monitor  and prevent migration of gas beyond the property
boundary.  The 18-inch thick clay cap was applied to 29  acres of the landfill.  These actions  were described
in the October 1983 Comprehensive Land Use and Operations Plan prepared in accordance with State landfill
closure regulations.  The  primary contaminants of concern affecting ground water include:  VOCs, TCE,
benzene, toluene, inorganics, chromium and lead.  Air is contaminated with methane gas and VOCs.

      The selected remedial action for this site includes: hydraulic control of the plume through installation
of ground water recovery wells; ground water pump and treatment using air stripping and, if necessary, carbon
filtration with discharge into an upgradient injection well  system; ground water monitoring; completion of the
landfill capping (29 acres  previously capped); continuation and  expansion, or  enhancement of the leachate
control and gas collection systems; and gas monitoring.  The estimated present worth cost of this remedial
action is $23,045,000.

PERFORMANCE  STANDARDS OR GOALS:  The plume will be  cleaned to  New  York State Department
of Environmental  Conservation (NYSDEC)  Standards and  Guidances,   and  Technical  and Operational
Guidance  Series, or to a zero-slope condition, if one exists  following five or more years of pumping and the
application of requisite remedial  technology.  If additional  compounds  should be detected (currently 17
inorganics and 25 VOCs specified), the  most stringent of the requirements obtained from these sources shall
apply.  For any VOC without a State value, the applicable  limit shall be 50 ug/1.  Some individual goals for
ground water include: chromium 0.05 mg/1, lead 0.025 nig/1, TCE  5.0 mg/1 (MCL),  benzene-non-detectable,
and toluene 50 mg/1.  Air discharge requirements will meet NYSDEC Air Guide No. 1.  If more stringent
Federal National Ambient Air Quality Standards  are promulgate, the more stringent standard shall apply.
Some individual goals for air (currently  27 specified) include:  methylene chloride 1.17 x 10 ug/m  , TCE 9.0
x 102 ug/m3, benzene 1.0  x 102 ug/m3, and toluene 7.5  x 103 ug/m3.

INSTITUTIONAL  CONTROLS:  Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                        REICH FARM, NJ
                                    First Remedial Action - Final
                                        September 30, 1988
ROD ABSTRACT
      The Reich Farm site is located in Dover Township, Ocean County, New Jersey.  The three-acre site
is bounded by commercial establishments to the west and wooded areas in all other directions.  The site is
approximately one mile northeast of the Toms River, but no floodplains or wetlands are affected by the site.
The site is currently owned by Mr. and Mrs. Samuel Reich.  In August 1971, they rented a portion of their
land to Mr. Nicholas Fernicola for temporary storage of used 55-gallon drums.  That December, the Reichs
discovered approximately 4,500  drums  containing wastes and 450 empty drums  on that portion of their
property.  Most of the drums had Union Carbide Corporation (UCC) markings on them, with labels reading
"tar pitch," "lab waste solvent," "blend of resin and oil," and "solvent wash of process stream" among others.
The site first  came to the attention of the New Jersey Superior Court when the Reichs filed suit against Mr.
Fernicola  and UCC.  UCC undertook drum removal and completed the work in March 1972.  In June 1974,
another 51 drums and approximately 1,100 yd  of contaminated soil and trenched wastes were removed from
the site, but residents near the site had already complained about unusual taste  and odor in their well water.
Based on results of an extensive sampling program, the Dover Township Board of Health ordered 148 private
wells closed and established a zoning ordinance restricting ground water use in the area of Reich Farm.  The
volume of contaminated soil  remaining  at the site is estimated to be 2,010 yd . The primary contaminants
of concern affecting the ground water and soils are VOCs including 1,1,1-trichloroethane (TCA), TCE, PCE,
and semi-volatile organics compounds (SVOCs).

      The selected remedial action  for this site includes:   additional ground water sampling to further
delineate the  leading edge of the  contaminant plume and additional  soil sampling to support existing data
on contaminants of concern  at the site; ground water  pump  and treatment using air stripping and carbon
adsorption with reinjection of the treated water back into the aquifer; excavation and storage of surface soils
onsite which  do not require  remediation; excavation of subsurface soils and onsite treatment by enhanced
volatilization  and onsite disposal, or shipment of subsurface soils which cannot be treated onsite to an offsite
RCRA-permitted facility for incineration and disposal, followed by  backfilling excavated areas with clean
surface soils.  The estimated  present worth cost for this remedial action is $5,832,000, which includes annual
O&M costs of $419,550.

PERFORMANCE STANDARDS OR GOALS: The cleanup objectives for ground water will meet the more
stringent State of New Jersey MCLs for TCA 26 ug/1, TCE 1 ug/1, and PCE 1 ug/1.  Cleanup  objectives for
the soil remediation will  meet the New Jersey Department of Environmental Protection Soil Action Levels
of 1 mg/kg total VOCs and  10 mg/kg SVOCs.

INSTITUTIONAL CONTROLS:   Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                RINGWOOD MINES/LANDFILL, NJ
                                    First Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The Ringwood Mines/Landfill site consists of approximately 500 acres in a historic mining district in
Ringwood Borough, Passaic  County, New Jersey.  The mines lie  west of and adjacent to the Town of
Ringwood and one mile northwest of Wanaque Reservoir. The site  is characterized by a variety of features
including abandoned mine shafts and surface pits, an inactive landfill, an industrial refuse disposal area, small
surficial dumps, a municipal recycling area, a municipal garage, and approximately 50  residences.  Ground
water beneath the site discharges to surface streams and the Wanaque Reservoir.  The Ringwood mines are
a series of iron ore  mines that operated from the mid-1700s  to the early 1900s and possibly even later. The
site was purchased by the U.S. Government prior to 1940, and later sold to a succession of owners including
Ringwood Realty Corporation  (RRC), a subsidiary of  Ford Motor Company (Ford), in January 1965.
Between 1967 and  1974, RRC  deposited waste products for Ford,  including car parts, solvents and paint
sludges, on the ground surface  and in  abandoned mine shafts.   In 1970, RRC donated 290 acres in the
southern portion of the site to Ringwood Solid Waste Management Authority (RSWM), which began operating
a permitted municipal disposal area in March 1972.  In 1976, the New Jersey Department of Environmental
Protection (NJDEP) closed the  landfill after determining that leachate emanating from the landfill was
contaminating surface water in the area. In July 1982, NJDEP detected moderate levels of VOCs, as well
as naturally  occurring heavy  metals, in  ground water in the northern section  of the site, which had been
retained by RRC and a portion  used for industrial waste disposal.  The site was subsequently divided into
four discrete  areas for investigation. Between October 1987  and February 1988, Ford International Services,
Inc., conducted a removal action, entailing excavation and  offsite disposal  of 7,000 yd  of surficial paint sludge
containing lead and arsenic from four onsite areas. Subsequent sampling, however, indicated  that soil within
a small area  (less than one acre) still contains concentrations of lead and total petroleum hydrocarbons in
excess of  health-based levels.  Furthermore,  there is sporadic and  moderate ground water  contamination,
generally confined to paint sludge locations, exceeding MCLs  for lead and arsenic. The primary contaminants
of concern affecting the soil and ground water are arsenic, lead, and petroleum hydrocarbons.

      The selected remedial  action for  this site includes: confirmatory sampling of soil with excavation and
offsite disposal of any soil exceeding health-based levels, followed by backfilling and revegetation; and ground
water, surface water and wetlands monitoring.  Since ground water in the vicinity of the paint sludge areas
is not used as a drinking water source and natural attenuation is expected to reduce contamination  levels of
below health  based levels after removal of the source, ground water will not be treated.  The estimated capital
cost for this remedial action is $225,000 with annual O&M of $50,000.

PERFORMANCE STANDARDS  OR GOALS:   Soil cleanup will attain the non-promulgated New Jersey
Cleanup Objectives  for lead 250  mg/kg and total petroleum hydrocarbons 100  mg/kg.  Ground water will
attain MCLs, including arsenic 50 ug/1  and lead 50 ug/1, by natural  attenuation.

INSTITUTIONAL CONTROLS:   Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                        ROCKY HILL, NJ
                                   First Remedial Action  - Final
                                           June 30, 1988
ROD ABSTRACT
      The 2-acre Rocky Hill Municipal  Well Field  site (RHMW) is located in Montgomery Township,
Somerset County, New Jersey.  Montgomery  Township Housing  Development  (MTHD), located north of
the well field contains  77 private homes.  RHMW is listed on both the State and  National Registers of
Historic Places.  Additionally, a nearby corridor has a potential for archaeological significance.  Two wells,
numbered 1 and 2, were constructed in 1936 to provide a source of potable water  to the Borough of Rocky
Hill (BRH).  A 1978 Rutgers University study revealed TCE contamination levels in Well 1,  and it was
abandoned and sealed by 1978. Further testing, conducted between 1978 and 1983, revealed cycles of elevated
levels of TCE in Well 2. It was closed in November 1979.  Declining levels of TCE in the well field resulted
in the reopening of the well; however, levels  increased and the well was  again closed in January of 1982.
During the shutdown of Well 2, BRH obtained potable water from the privately-owned Elizabethtown Water
Company.  After the installation of two air stripping  units by the borough, Well  2 reopened as a potable
water source. Recently, 38 MTHD residents elected to connect to the municipal supply. The first operable
unit ROD, signed in September  1987,  provided for the  supply of  alternate water through the permanent
hookup of all remaining MTHD residences and 6 residences outside of MTHD. Approximately 13 possible
sources of contamination  are  under evaluation.  TCE is the most predominant  site contaminant, both with
respect to concentration and areal extent.  Several additional components such  as  chlordane and metals are
sporadically present; however, these compounds were not considered  to be related to the TCE contamination.

      The selected remedial action for this  site  includes:   ground water pump and treatment using air
stripping with reinjection;  connection of any remaining affected residences to the public water supply;  sealing
remaining private water supply and monitoring wells within the contamination plume; and implementation of
ground water sampling  program to monitor the effectiveness of the  cleanup. The  estimated capital cost for
this remedial action is $1,618,000 with annual  O&M of $84,000.

PERFORMANCE STANDARDS OR GOALS:  The objective of remediation is to  reduce the entire ground
water concentration of TCE  to 1 ug/1.  This level is a proposed New Jersey MCL which is expected to be
promulgated in the near  future.   It is being used  in place  of  the  federal MCL of 5 ug/1.   PCE and
1,1-dichloroethene will be  reduced to below 1 ug/1 and 2 ug/1, respectively. The remedy will meet a 0.12
x 10  excess cancer risk  level.

INSTITUTIONAL CONTROLS:  In January 1986,  the New Jersey Department of Environmental Protection,
Division of Water Resources, placed a restriction on future well drilling  for water  supply wells in the area.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                 TABERNACLE DRUM DUMP, NJ
                                    First Remedial Action  - Final
                                            June 30, 1988
ROD ABSTRACT
      The Tabernacle  Drum Dump (TDD) site is a one-acre  parcel of  undeveloped land located in
Tabernacle Township,  Burlington  County,  New  Jersey.    Drum  disposal  activities,  which resulted in
contamination by hazardous substances,  occurred on  a 2,000 ft  area portion of the site.  Land use in the
area consists  mainly of woodland, bogs, agriculture  and recreation.  The soils typically found in the area are
highly permeable, sandy, and acidic.  Approximately 75 to 100  residents live within a one-mile radius of the
site.  Most of the residents located down-gradient of the site  depend on individual residential wells for
potable  and agricultural purposes.  TDD is  currently  owned by  Mr. and Mrs. Phillip  Myers.  In 1976 and
1977, the property was occupied  by Mr.  and Mrs. Robert Ware.  During that period, Mr. Ware's employer,
the Atlantic Disposal Services (ADS), disposed of approximately 200 containers, including fifty-five gallon
drums, twenty gallon containers, and five gallon paint cans.  These containers were stored at the site between
1977 to 1984.  Deterioration  and leakage of some  containers  resulted  in visible soil  contamination and
ultimately ground water contamination.   Based  on  a referral  from  Tabernacle Township officials, the
Burlington County Health Department conducted a site inspection in August 1982, and discovered over 100
abandoned drums. In November 1982, the New Jersey Department of Environmental Protection (NJDEP)
conducted a more detailed site  inspection. Leaking  and deteriorated drums containing solvents, paint sludges,
heavy metals,  and visibly contaminated surface soils were revealed.  In 1984,  EPA issued an administrative
order to ADS requiring  it to perform a surface cleanup of the site, install and sample four monitoring wells,
and  sample and analyze site surface and subsurface soils for priority pollutants.  During April 1984,  ADS
initiated some remedial  measures including the numbering, logging and sampling of site containers.  Surface
cleanup was completed  in July 1984 and consisted of removing  containers, 40 yd  of  drum  material,  eight
truck loads of excavated soil, and approximately 3,000 gallons of liquid material. The principle threat posed
at the site is  potential ingestion of ground water by down-gradient  residents.  The primary contaminants of
concern are VOCs including 1,1,1-trichloroethane (TCA) and 1,1-dichloroethene (DCE).

      The selected remedial action for this  site includes:  installation of ground water monitoring wells to
further  delineate  the extent of the  plume and implementation of a monitoring program for  downgradient
residential wells; ground  water pump and treatment using air stripping and possibly carbon adsorption followed
by reinjection, ground water monitoring  and exhaust  gas  analysis; and  soil  sampling  of the former  drum
dumping and  storage area.  The estimated capital cost for this remedial action is $772,600 with present worth
O&M of $215,600.

PERFORMANCE STANDARDS OR GOALS: The proposed MCLs established by NJDEP are more stringent
than federal standards and include 1,1,1-TCA 26 ug/1 and DCE  2 ug/1.  The remedial action will comply with
NJDEP levels in anticipation that they will become State ARARs.  The levels of contaminants found in the
surface  soils did not exceed the existing soil  ARARs established  by NJDEP.

INSTITUTIONAL CONTROLS:   Not applicable.
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                      Progress Toward Implementing Superfund:  Fiscal Year 1988
                           UPJOHN MANUFACTURING COMPANY, PR
                                    First Remedial Action - Final
                                          September 30, 1988
ROD ABSTRACT
      The Upjohn Manufacturing  Company (UMC) site is  located in the Barceloneta industrial park  on
the north coast of Puerto Rico.  Land use in the surrounding area is  industrial, agricultural, and rural
residential. The site is in a sparsely populated rural region and lies above the island's largest aquifer, which
serves as a source of drinking water for over 12,000 area residents. In addition, the aquifer discharges to a
wetland area to the north, which supports a large aquatic and bird population. The site lies in a limestone
region characterized by karst terrain developed by dissolution of the existing limestone formations and typified
by closed depressions, sinkholes, and subsurface conduits.   Between  August and  September  1982, UMC
dispatched approximately  15,300 gallons  of a manufacturing by-product  waste  mixture estimated to  be
comprised of 65 percent carbon tetrachloride and  35 percent acetonitrile  to a leaking underground storage
tank (UST), resulting in  the release of all of the waste into the ground.  Investigation by UMC  determined
that  carbon tetrachloride contamination had  migrated  offsite approximately two miles to the north and
occupied an area of  about 2.1 mi .  Consequently, five local water supply wells were closed in 1982 due to
the potential for carbon tetrachloride contamination, and UMC provided a permanent alternate water supply
to users.  In 1983, UMC began implementing remedial actions to remove carbon tetrachloride from the soil
and ground water:  this  included the  installation and operation of a vacuum extraction system until March
1988; ground  water  pumpage from the AH  Robins well adjacent to and north of the site  until 1985;
installation and operation of a second ground water contaminant recovery extraction well, UE-1, on the UMC
facility in 1984, with air stripping and residual discharge to a sinkhole; and placement of a concrete cap over
the tank farm.  In 1987, because of residual ground water contamination that has  remained both on and
offsite, EPA ordered UMC to continue its remedial activities including resuming operation of the vacuum
extraction system,  pumping extraction well UE-1, and ground water monitoring, as well  as determining the
feasibility of restoring all or portions of the aquifer to health-based levels.  This ROD addresses the residual
ground water contamination resulting from the 1982 UST leak at the UMC  facility. The possibility of residual
contamination in the soil as a continuing source of carbon tetrachloride contamination in the ground water
will be addressed by the  EPA RCRA program  and will not be a  part of this remedial action.  The primary
contaminant of concern affecting the ground water  is carbon  tetrachloride.

      The selected remedial  action for this site includes:  ground water pump and treatment from the UE-1
and AH Robins wells using air-stripping, followed  by discharge of the treated water  to an existing sinkhole;
ground water pump and  treatment using air  stripping from  the public supply well followed by distribution to
the public water supply system; installation and operation of two to four additional offsite extraction wells with
air stripping and recharge to the ground water;  installation of chloride monitoring wells near the  coastline to
monitor potential salt-water encroachment; and  long-term ground water monitoring.  Because it is not known
whether contaminant levels in the aquifer can  be  reduced to the MCL, EPA will re-evaluate this remedy
within five years of operation to determine the allowable contaminant levels that must  be  met before the
extraction wells are shut down.  If  a decision is made that any portion of the aquifer will not be restored,
a waiver from  the MCL for reasons  of technical impracticability will be evaluated at that time.  The estimated
capital cost for this interim remedial action is $2,200,000-$6,200,000 with annual O&M of $400,000-$700,000.

PERFORMANCE  STANDARDS OR GOALS:  Ground water cleanup levels will meet the MCL for carbon
tetrachloride of 5 ug/1.

INSTITUTIONAL CONTROLS:  Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                          YORK OIL, NY
                                        First Remedial Action
                                          February 9, 1988
ROD ABSTRACT
      The York Oil  Company site, encompassing 17  acres,  is located  in the Hamlet of Moira, Franklin
County, New York.  Wetlands and woodlands are the principal land use in the vicinity of the site. Residences
exist along the main roads interspersed with active/inactive agricultural and pasture land.  The now dissolved
York Oil  Company operated  a waste oil recycling facility from approximately 1964 to  1977.  Crankcase
industrial oils,  some containing PCBs, were collected from sources throughout New England and New York,
then stored and/or processed at the site in eight above-ground storage tanks, a series of three earthen-damned
settling lagoons,  and at least one below-ground storage tank.  The recycled PCB-contaminated oil was either
sold as No. 2 fuel oil or used in dust control for the unpaved roads in the vicinity of the site.  During heavy
rains and spring thaws, the oil-water emulsion from the lagoons would often overflow onto the surrounding
lands.  In 1964,  in lieu of paying damages to adjacent farm-owners, the  oil company purchased land in the
area of the spills.  The  York Oil  site  contamination  was first discovered in  1979 by a New York State
Department of  Transportation  road  crew,  who then  notified  the New York  State Department  of
Environmental Conservation (NYSDEC). Several interim  actions have been undertaken at  the site to contain
the  PCB-contamination  problem.   Currently,  soils,  sediments,  ground  water  and  surface  water  are
contaminated with PCBs, VOCs, metals and phenols.

      The selected  remedial action for  this site includes:   excavation  of approximately 22,000  yd   of
contaminated soil and approximately 8,000 yd  of contaminated sediments with  onsite solidification followed
by onsite  disposal of treatment residuals; installation of deep ground water drawdown wells  and  shallow
dewatering wells to collect the sinking contaminant plume and the oil during excavation, with onsite treatment
and  subsequent  discharge  in  accordance with  New York State discharge requirements; offsite  thermal
treatment of approximately 25,000 gallons of contaminated tank oils in addition  to other 'oils collected at the
site; cleaning and demolition of the  empty storage tanks; and grading.  Treatability studies will be conducted
during remedial design to determine the effectiveness of the solidification process in  meeting specified
treatment levels  and to determine the optimal treatment system for ground water.  The estimated capital cost
for this  remedial action is $6,500,000 with present worth O&M of $500,000.

PERFORMANCE STANDARDS OR GOALS:  The cleanup level for PCBs in soil of 10 mg/kg was derived
based on the current New York State goal to clean up  uncontrolled PCB sites in residential areas to a level
less than 10 mg/kg, and on the Toxic Substances Control Act PCB Spill Clean Policy which states that "PCB
spills in residential areas ... [should] ...  be remediated  to  10 mg/kg."  The clean level for total phenols in
ground water is  100 ug/1 in accordance  with New York State Ambient Water Quality Guidelines.

INSTITUTIONAL CONTROLS:  Not applicable.
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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                      ALADDIN PLATING, PA
                                        First Remedial Action
                                         September 27, 1988
ROD ABSTRACT
      The two-acre Aladdin Plating  site  is a former electroplating facility located in Scott  and Abington
Townships, Lackawanna  County, Pennsylvania, approximately 1.5  miles north  of the Town  of Chinchilla.
The area surrounding the site is wooded, with four residences within 100 yards  and about 120 people living
within a 0.25 mile radius. Approximately 11,000 people within three miles of the  site use domestic and public
ground water  wells  for  drinking water.  Site runoff flows northwest toward Leggetts Creek, a  principal
tributary of Griffin Pond Reservoir.  Leggetts Creek  and Griffin Pond are sources of supplemental drinking
water for more than 100,000 people.   The nearest  residential well is  less than 1,500  feet  from the site.
Aladdin  Plating conducted  electroplating operations from  1947 to 1982.  Hazardous  materials used  in
operations  include sulphuric acid, chromic acid,  cyanide, chromium and other heavy metals.  For 35 years,
electroplating  waste  effluents containing heavy metals and other contaminants were discharged via a ditch
and underground pipes to a  shallow surface lagoon  near  the electroplating building.  A fire destroyed the
facility and ended operations in 1982.  Three source areas of contamination have been  identified:  the site
of the former  plating facility building, a buried trench (presumably the building's  floor drain), and the lagoon.
In 1983, chromium was detected in onsite  soils.  Subsequent testing by EPA in 1984 also identified lead and
cyanide in  onsite soils.  In addition, ground water samples from onsite  monitoring wells showed significant
levels of arsenic, cadmium, chromium, and lead; all exceeded their respective MCLs.  In March 1987, EPA
performed  emergency  response  activities to remove  significant immediate health threats.  These responses
included fencing contaminated  zones  and removing drums  and vats  containing hazardous  wastes.   This
response action  addresses  only the  remediation of the  contaminated  soil  onsite.   The  ground  water
contamination will be  addressed in a  subsequent  remedial  action.   The  primary contaminants of  concern
affecting the soil and ground water are arsenic, chromium, and lead.

       The selected remedial action for this site includes:  excavation and offsite stabilization of approximately
12,000 yd3  of  contaminated soil, with disposal of the treated soil in an offsite landfill and replacement of the
excavated soil with  clean fill.  The estimated present worth cost for this remedial  action is $4,461,000 with
no associated  O&M costs.

PERFORMANCE STANDARDS OR GOALS:    Soils will be excavated to  a  depth  where chromium
contamination is 50  mg/kg or less.

INSTITUTIONAL CONTROLS:  Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  AMBLER ASBESTOS PILES, PA
                                        First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The Ambler Asbestos Piles site  is located in the southwestern portion of the Borough  of Ambler,
Montgomery County, Pennsylvania.  Land around the site is used for industrial, residential, commercial, and
transportation purposes.  The site is bordered on the west by Wissahickon Creek and its flood plain.  A low
density housing  development lies to  the  southwest.  The site  consists  of four  distinct  areas  of asbestos
contamination: the Locust Street  Pile, the Plant Pile, the  Pipe Plant Dump,  and  the asbestos settling
basins/filter bed lagoons.  The waste piles of concern in this operable unit are the Locust Street Pile and the
Plant Pile.  Within a 0.25 mile radius  of the Locust Street  Pile are approximately 40  residences and a public
playground that was closed in  1984.  The  K&M Company owned and operated the site from the late 1800s
to 1962 and produced asbestos products such as paper, millboard, electrical insulation, linings, conveyor belts,
and high pressure peckings. The primary wastes generated and disposed of in the Locust Street and Plant
Piles during that period were spent magnesium/calcium (from pharmaceutical operations) and asbestos process
waste.  In 1962,  Certainteed Corporation purchased a portion of the site and  facilities from K&M  and
manufactured asbestos-cement pipe at the plant. Nicolet Industries, Inc. purchased the remainder of the site
and manufactured asbestos millboard  and monolithic products.  The Locust Street Pile continued to receive
asbestos waste from Nicolet until sometime after 1964; however, waste continued to be deposited on the Plant
Pile  until  1980.  EPA  and the  Pennsylvania Department of Environmental Resources conducted their first
investigation of the site in 1971, noting visible emissions  and substantial dust concentrations attributed to
asbestos. Subsequent investigations of the surface water, bulk waste samples, and air samples in 1983 revealed
asbestos contamination. In September 1983, the Centers for Disease Control issued a Public Health Advisory
recommending the closure of the nearby playground.  In 1984, EPA implemented emergency response actions
to establish a soil and vegetative cover, install a drainage system, and provide erosion control measures over
the Locust Pile.  In addition, Nicolet had covered the Plant Pile  by June  1984.  The  primary contaminant of
concern affecting the sediments, surface water,  and  debris is  asbestos.

      The selected remedial action for this site includes:   installation  of a geotextile and soil cover on the
exposed areas of waste piles; erosion control/repair on waste pile slopes to facilitate vegetation; pump and
treatment (using  filters) of surface water  from lagoon and settling basins with onsite discharge, backfilling
and  regrading lagoon  and settling  basins to  promote positive  drainage and  onsite  disposal of collected
sediments and asbestos on the waste piles; implementation  of slope  stability control  measures, if deemed
necessary  after testing; installation of gabions or rip-rap to  prevent scouring action of Wissahickon Creek
on the waste piles; runoff collection and treatment; preparation of a contingency plan; and access restructions.
The estimated capital cost for this remedial action is $5,135,000, with estimated annual O&M costs of $46,000
to $63,000  for years 2 through 6 and  $33,000 for years 6  through 30.

PERFORMANCE STANDARDS OR GOALS:   Remedy  addresses containment of asbestos-contaminated
debris; therefore, no cleanup  level is provided for the debris.   Surface water treatment will  meet State
NPDES requirements.  Individual cleanup goals not provided.

INSTITUTIONAL CONTROLS: Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                       AVTEX FIBERS, VA
                                       First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The 440-acre Avtex Fibers site is  located in Warren County, Front Royal, Virginia.  The facility is
bounded to the west  and northwest by  the Shenandoah River and  to  the  south, northwest,  and east by
residential areas.  Approximately 1,300 people live within one mile of the site.  The western part of the site
lies within  the  limits of the Shenandoah  River's 100-year floodplain.  The Avtex Fibers site has produced
rayon fibers since 1940, polyester between 1970 and 1977, and polypropylene since 1985.  During this 48-year
period, byproducts from the rayon manufacturing process were  disposed of in onsite surface impoundments.
These byproducts included sodium cellulose xanthate-based viscose and zinc-hydroxide sludge. Fly ash (from
incinerator exhaust air pollution control devices) and boiler house solids were disposed of in five other surface
impoundments.  Land disposal  of viscose waste ceased in 1983; since that time, the waste has  been routed
directly to an onsite wastewater  treatment plant.  In 1982, carbon disulfide, a constituent of viscose waste, was
identified in ground water samples from residential wells located across the Shenandoah River from the site.
In response to the results of a ground  water  investigation, Avtex  implemented interim  measures,  which
included purchasing 23 subdivision properties on the west side  of the river that had contaminated domestic
wells, and initiating a ground water pump and treatment program.  This ROD is the first of two operable
units  and  addresses ground water remediation  and  interim  remedial  measures  for the viscose  basins
responsible for ground water contamination. A subsequent  remedial action will address source control and
viscose basin remediation. The  primary contaminants of concern affecting the ground water are  phenols, and
metals including arsenic and lead.

      The selected remedial action for this site includes: ground water and basin liquid pump and treatment
in the existing onsite activated sludge wastewater treatment plant, following completion of necessary upgrades,
modifications,  and  construction of pretreatment  units, with  offsite discharge of  treated water  to the
Shenandoah River; monitoring on- and offsite ground water,  surface water, and basin fluids; and  placing deed
restrictions prohibiting the use of ground water on the  affected properties. The estimated present worth cost
for this  remedial action is $9,122,000.

PERFORMANCE STANDARDS OR GOALS: Ground water will be treated to meet MCLs, EPA References
Dose-based water limits,  Federal AWQC  and State Drinking Water Standards.  Individual  goals include
phenols 0.3 mg/1 (AWQC), lead 0.05 mg/1 (MCL/VAGWS), and arsenic 0.05  mg/1 (MCL/VAGWC).  When
the aquifer restoration goals are attained, the hazard index for  ingestion  of ground water will be less  than 1
for the noncarcinogen contaminants in the  ground water.

INSTITUTIONAL CONTROLS: Deed restrictions will be implemented to prohibit the  use of ground water
on the affected properties.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                            BENDIX, PA
                                    First Remedial Action - Final
                                         September 30, 1988
ROD ABSTRACT
      The Bendix  site is an  aircraft instruments manufacturing plant located  near the  Village of South
Montrose, Bridgewater Township, Susquehanna County, Pennsylvania.  The  60-acre site  is situated in a
sparsely populated area (approximately 500 people) atop a topographic divide between the Meshoppen Creek
and Wyalusing Creek watersheds.  Natural ground water discharge areas exist  east of the site in a wetlands
area of Meshoppen Creek, and west of the site at the headwaters of Wyalusing  Creek.  South Montrose is
solely dependent  on private ground water wells for water.  The Bendix Corporation (Bendix) acquired  the
parcels of land comprising the site in 1951 and 1952, was acquired by Allied Corporation (Allied) in 1983,
and finally merged  into Allied in 1985.  Allied is the current owner of the property.  From 1952 to 1958
industrial solvent  wastes were  disposed  of in a lagoon northeast of the plant,  and for several years similar
wastes also were disposed of in a series of onsite small trenches east of the plant.  In addition, from the early
1950s until 1978, an earthen disposal pit  installed by Bendix was used for the disposal of water-soluble cutting
oil and oil-contaminated water from air compressors.  The basin was drained of  free liquids, backfilled, and
seeded in late 1978. Investigations performed by Bendix from 1984 through 1987 indicated  that as a result
of past disposal practices,  contamination from subsurface soil has been leaching  into the underlying ground
water.  Five source areas  of contamination have been identified at  the site: a TCE storage tank area,  the
pet/trench area, an old landfill area, the area of a former solvent evaporation facility, and  a former drum
storage area behind the plant building.  Bendix is currently supplying carbon filter units to users of affected
wells. The primary contaminants of concern affecting the ground water and soil are VOCs  including TCE.

      The selected remedial action for this site includes:  soil vacuum extraction and soil aeration; onsite
ground water pump and treatment with air  stripping; and treatment of offsite ground water contamination
through carbon adsorption at the well heads.  The estimated present worth cost for this remedial action is
$4,487,000 with annual O&M costs of $542,000.

PERFORMANCE STANDARDS OR GOALS:  Both on- and offsite ground water cleanup goals have been
set at less than 1  ug/1 TCE.  Soil will be cleaned to 100 ug/kg leachable VOCs  based on the ground water
cleanup  goal.

INSTITUTIONAL CONTROLS:   Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                      BERKS SAND PIT, PA
                                    First Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The three to four-acre  Berks Sand  Pit  site  is located in Longswamp Township, Berks County,
Pennsylvania.  There are at least 20 single family homes within the investigation area, including one on top
of the actual sand pit. The immediate vicinity of the site is zoned for low density residential use. The Berks
Sand Pit was created by the removal of sand and gravel, but reportedly was used by area residents for refuse
disposal. Industrial waste also was alleged to have been disposed of in the area around the pit.  Houses were
constructed and private wells installed at the location beginning in 1978, after the pit was backfilled.  The site
first came to the attention of EPA in January 1982 when area residents detected ground water contamination.
Emergency actions were undertaken by EPA in the summer of 1983.  The pit was partially excavated and
backfilled  with clean fill, but no  pocket of  contamination was  discovered.   The primary contaminants of
concern affecting the ground water, surface water, and sediments are VOCs including 1,1,1-TCA,  1,1-DCA,
PCE, and 1,1-DCE.

      The selected remedial action for this site includes:  excavation of contaminated sediments with offsite
treatment  by incineration; ground water pump and treatment us*'ng air  stripping and vapor  phase carbon
absorption with  reinjection of  treated water back into  the aquifer; provision of an alternate water  supply
system,  surface and ground water monitoring; and restrictions to prevent  installation of drinking water wells
in the contaminated aquifer. The estimated present worth cost  for this remedy is $10,773,100, with annual
O&M costs of $459,200.

PERFORMANCE STANDARDS OR  GOALS:  Ground water cleanup  goals will attain health-based  MCLs
for 1,1,1-TCA  200 ug/1 and 1,1-DCE  7 ug/1. Secondary target levels, based on published Unit Cancer Risk,
will be met for 1,1-DCE and PCE 1.0 ug/1.  Reinjection of treated ground water into the  aquifer  will meet
Underground Injection Control  requirements.

INSTITUTIONAL CONTROLS: Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                      CHISMAN CREEK, VA
                                    Second Operable Unit - Final
                                          March 31,  1988
ROD ABSTRACT
      The Chisman Creek site is located near Grafton  in York County, Virginia.  This ROD addresses
operable unit two, which consists of three ponds (designated A, B, and C), the freshwater tributary, and the
Chisman Creek estuary.  The site is located within the  watershed of Chisman Creek,  a tributary of the
Chesapeake Bay.  Approximately  500 to 1,000 people live within one mile of the site.   Between 1957 and
1974, fly ash from the Virginia Power Yorktown Power Generating Station was disposed of in four abandoned
sand and gravel borrow pits located  approximately two miles south of the generating station.  The fly ash
disposal areas, designated Areas  A,  B,  C,  and D, became known  as the Chisman Creek Superfund site.
Between 1971 and 1973, all fly ash in Area D was removed and deposited in Area C. Area D was reportedly
filled with construction rubble generated during the construction of  public utilities in  the area at that time.
After a  domestic well showed discolored water in 1980, the Virginia State Water Control Board (SWCB) and
Virginia State Board  of Health sampled residential ground water  in the vicinity  of the  fly  ash  areas to
determine the types and concentrations of contaminants present.  The Virginia Institute  of Marine Science
and SWCB conducted additional studies to determine the nature and extent of area contamination.  The first
operable unit ROD  was signed in  September 1986.  The remedial action, begun in November 1987, includes:
placing  a  soil  cover on two areas and a clay cap on  a  third area; relocating  a  portion  of the tributary;
providing an alternate water supply for residential areas; and post-closure monitoring. At the request of EPA,
the U.S. Fish and Wildlife Service conducted the second operable unit remedial investigation to evaluate the
impact of contaminants at the site on fish and wildlife resources and their habitat.  Chemical analysis of the
physical environment and biota of  the site for operable unit two focused on eight metals. These were arsenic,
cadmium, copper, lead, nickel, selenium, vanadium, and zinc. The most ubiquitous and abundant metals were
nickel and vanadium.   Bioassays showed the surface water quality  in Ponds B and C to be below ARAR
levels, and sediment from the  Chisman  Creek estuary to have no adverse impacts from the contaminants.
Fish from the freshwater ponds and  oysters from  Chisman Creek have not been impacted. Human health
risks from  consumption of fish  and oysters, or  accidental ingestion  of surface water  and sediments are all
within EPA guidelines for acceptable risks.  The primary contaminants of concern affecting surface water in
Area A include nickel and vanadium.

      The selected  remedial action for this site includes:  diversion of surface runoff from Area A (covered
with soil in Operable Unit One) into Pond A and water quality monitoring to evaluate the effectiveness of
both operable units.  The estimated present worth cost for this remedial action is  $137,000.

PERFORMANCE STANDARDS OR GOALS:  An ARAR for vanadium has not been promulgated. However,
EPA has recently developed an unpublished Estimated Advisory Concentration for vanadium of 7.7 ug/1 which
will be met in freshwater systems.  Remediation will attain the Clean Water Act level  for  nickel 13.4 mg/kg.

INSTITUTIONAL CONTROLS:   Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                               DELAWARE SAND & GRAVEL, DE
                                    First Remedial Action - Final
                                           April 22, 1988
ROD ABSTRACT
      The Delaware Sand &  Gravel  (DS&G) site is a 27-acre inactive industrial waste landfill located in
New Castle County, Delaware.  It is  bordered by Army Creek to the west, Army Creek and wetlands to
the north, residential and business facilities  to the east and an abandoned sand and gravel quarry to the
south.   Also to the west of the site directly across  Army  Creek is the Army Creek Landfill NPL site.
Residences are located  approximately 30  feet from  the landfill and  a  residential development is located
approximately 0.5 miles  south and southwest of  the site.  Underlying the landfill is  the Potomac Aquifer,
which is accessed about 1.25 miles south of the  site and used as a public water source.   The DS&G site
consists of four disposal areas,  referred to  as the Drum Disposal, Inert Disposal, Ridge, and Grantham
South areas.  Between 1968 and 1976 the site accepted household and construction wastes and approximately
7,000 drums containing liquids and sludges from  perfume, plastics, paint, and petroleum refining processes.
In 1971, investigations revealed ground water contamination emanating  from the Army Creek and DS&G
landfills.  In 1976, the Delaware Department of Natural Resources  and Environmental Control issued  an
enforcement action requiring DS&G to discontinue disposal activities.  A ground water recovery system was
installed to prevent contaminated water from reaching the nearby private wellfield, which continues to operate.
Investigations were conducted to characterize the source and  extent of contamination from both sites, and in
1984 EPA initiated an emergency removal action at the DS&G site to remove approximately 600 drums from
the Drum Disposal area.  An  estimated 535,000 yd  of waste material are located onsite. Wastes identified
in the Drum Disposal area include subsurface soil and debris contaminated with PCBs, organic liquids, and
inorganic solids.  The Drum  Disposal area is believed to be the major source  of  organic ground  water
contamination.  The Ridge area consists of contaminated surficial soil and drums,  storage tanks, and debris
scattered on the surface.  The Inert Disposal area contains various domestic waste, cars, trucks, and storage
tanks scattered on the surface.  The Grantham South area is believed to  contain surficial inert waste as well
as deposited chemical wastes.   Two hot spots of organic contamination were identified in this area.  The
primary contaminants  of concern affecting the soil and ground water are VOCs including  benzene, toluene
and xylenes, other organics including PCBs, PAHs and phenols, and metals including chromium and lead.

      The selected remedial  action for this site includes:   excavation and onsite  mobile incineration of
approximately 36,000 tons of contaminated soil and  wastes from the  Drum Disposal  and  Ridge areas, with
on- or offsite disposal of residual ash and  grading and revegetation  of excavated areas; removal and offsite
disposal of all  surface debris material from  the  Inert area,  followed by capping;  construction of  a RCRA
cap over the Grantham  South area; ground water pump and treatment with  discharge to  Army Creek; and
ground  water monitoring. The estimated present worth cost for this remedial action  is $24,944,000.

PERFORMANCE STANDARDS OR GOALS: The ground water remedy will result  in MCLs or  10"6 risk
levels being met at the site boundary.  Ground water treatment will attain the levels specified in the NPDES
regulations before being discharged  to Army Creek.  Individual goals were not specified.  Excavation  in the
Drum Disposal area will attain soil contaminant levels based on acceptable drinking water exposure, including
toluene 6,000 mg/kg, xylene 4.8 mg/kg and phenol 497 mg/kg.

INSTITUTIONAL CONTROLS:  Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                 DORNEY ROAD LANDFILL, PA
                                       First Remedial Action
                                        September 29, 1988
ROD ABSTRACT
      The Dorney Road Landfill site is located in Lehigh County, Pennsylvania.  The site is approximately
27 acres, bounded on the east by Dorney Road, and extends westward such that the southwest corner is in
Longswamp Township, Berks  County.   Land use in the area is rural,  residential, and agricultural.   The
population within an  0.25 mile radius of the site is estimated to be approximately 20 people.  Currently, one
residence is located within 1,000 feet of the site and three residences are within 2,000 feet of the site.  The
water supply for these nearby homes is ground water from private wells.  Beginning in 1952, an abandoned
iron mine pit  on the site was used  as  an  open dump.   From 1966 to 1978,  an  unpermitted landfill was
operated in the same mine pit. In 1986, EPA conducted a removal action and regraded the landfill to prevent
runoff and erosion of landfill material from migrating to neighboring  property.   In  1980 and  1982, EPA
investigations revealed elevated levels of VOCs, metals and phenols  in ground  water and leachate  samples.
This remedial  action  will prevent dermal contact and incidental ingestion of landfill soil  and solid waste.  It
will also minimize the continued leaching of  precipitation  and onsite ponded waters through the contaminated
landfill.    A subsequent  remedial  action will  address the ground  water under  the site.   The  primary
contaminants of concern affecting the soil,  ground water, and surface water are  VOCs  including  benzene,
toluene, and xylenes,  metals including arsenic and chromium, and other organics including phenol and PAHs.

      The selected remedial action for this site includes:  offsite disposal  of approximately  700,000 gallons
of onsite pond water; construction of a dike and diversion ditch system to control runon/runoff; regrading
and installation of a multi-layer landfill cap  and a gas collection system; ground water monitoring; and deed
and access restrictions.   The estimated present worth  cost  for this remedial action  is $14,000,000 with
estimated  annual O&M  costs of $42,000.

PERFORMANCE STANDARDS OR GOALS:   The remedy will reduce the cancer risk to  below  the 10"6
level.

INSTITUTIONAL CONTROLS: A notice will be placed on the land deed within  site boundaries.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                 DOUGLASSVILLE DISPOSAL,  PA
                                       Second Remedial Action
                                            June 24, 1988
ROD ABSTRACT
      The Douglassville Disposal site occupies  approximately 50 acres of land  in Union Township, Berks
County, Pennsylvania.  It is almost entirely within the 100-year floodplain of the Schuylkill River.  In 1941,
Berks Associates began recycling lubrication oil at  the site; waste solvents were recycled in the 1950s and
1960s.  Wastes generated from those recycling processes were stored in onsite lagoons from 1941 until 1972.
In November  1970, heavy rains caused the lagoons  to overflow and release 2,000,000 - 3,000,000 gallons  of
wastes down the Schuylkill River.  Federal and State actions were initiated to dispose of  the waste material
remaining in the lagoons.   Before this action could  be carried out, heavy rains from  a hurricane caused the
river to overflow its banks and inundate the entire site area in June 1972. An estimated 6,000,0000 - 8,000,000
gallons of wastes were carried by floodwaters downstream for about 15 miles. During cleanup after the storm,
the lagoons were drained  and backfilled by EPA. Lubrication oil recycling operations continued at the site
until 1979 when  the operator determined operational correction, mandated by the Pennsylvania  Department
of Environmental Resources (PADER), were cost  prohibitive.  Operations then turned  to the practice  of
refining waste oils for  use as fuel in industrial boilers.  Beginning in 1979, oily waste sludge  from the new
recycling process was landfarmed onsite.   This practice was  halted  in 1981 when PADER mandated
operational corrections to the landfarming practices. In late  1985, all oil recycling operations at the facility
were completely discontinued. This operable unit addresses the 3-4 acre area in the southern most portion
of the site  and is hvdraulically upgradient of the rest of the site. The area consists  of a concrete  building,
process equipment, piping, and at least 57 process tanks.  The tanks are constructed of wood,  concrete,  or
steel and range in size from 3,000 gallons to 600,000  gallons.  Approximately 200,000 gallons of PCB and lead
contaminated  oil and waste sludges remain in the tanks.   The buildings, tanks,  tank wastes, and processing
equipment  are impediments to any future  soil and ground water remediation and are a source of continuing
contamination of these media. The primary contaminants of concern include: VOCs,  PCBs, PAHs, and lead.

       The  selected remedial action for this site includes:  removal of liquid and  sludge  tank waste  with
transportation to an offsite incineration facility; decontamination of tanks, piping, processing equipment, and
building materials;  offsite disposal of building rubble, selling of tanks and other metal materials as scrap;
offsite disposal of concrete, asphalt, and other materials; and treatment of generated  decontamination fluids,
as appropriate. The estimated capital cost for this remedial action is $4,050,000.  No  O&M will  be incurred.

PERFORMANCE STANDARDS  OR  GOALS:  Tanks, piping, processing equipment and building materials
designated  for salvage or  reuse will be decontaminated to a level  not to  exceed 100 ug/100  cm  PCBs  on
the surface, as determined by wipe sampling.  Concrete,  asphalt, other materials containing PCBs, and any
others which  cannot  be decontaminated  to  less than 50 mg/kg PCBs, will be disposed  of at an offsite
hazardous waste landfill. This operable unit remedy does not attempt to ensure compliance with all ARARs
for the entire  site, but will not be inconsistent with  a  final comprehensive remedy for the site.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-48

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     DRAKE CHEMICAL, PA
                                    Third Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The Drake Chemical Site is a 12.5-acre inactive chemical manufacturing facility located in Lock Haven,
Clinton County, Pennsylvania. The area surrounding the site includes American Color and Chemical Company
to the west, Hammermill Paper Company to the southwest, Bald Eagle Creek to the south, the west branch
of the Susquehanna River to the north, and an apartment complex and a shopping center to the east.  Bald
Eagle Creek and the Susquehanna River are wetland  areas and are used for recreation and fishing.  Lock
Haven residents do not use ground water for  drinking purposes. The facility operated between 1951 and 1982
manufacturing chemical  intermediates  used in producing dyes, cosmetics, textiles,  pharmaceuticals,  and
pesticides.  The site includes two synthetic-lined wastewater treatment lagoons, an unlined  leachate lagoon,
and a dry unlined sludge lagoon. The water and sediments within the two lined impoundments are highly
contaminated with site-related  organic and inorganic contaminants.  The site surface is covered with debris,
chemical sludge,  and  contaminated soil.   Approximately 252,000 yd  of soil,  sludges, and sediments are
contaminated.  The Drake Chemical Company was cited several times by  State and Federal agencies for
violating environmental and health and safety regulations.  In 1982, EPA began an emergency removal action
in which surface drums, surface sludges, and liquids contained in process and storage tanks were removed and
disposed of, and the site was fenced. A ROD  signed in 1982  addressed the leachate stream that ran offsite
towards Bald Eagle Creek, and remediation was completed in 1987.  A subsequent ROD signed in May 1986
required demolition of onsite contaminated buildings and tanks, and  disposal in an offsite landfill.  This work
currently is being undertaken.  The focus of the remedial action addressed in this ROD is remediation of the
contaminated soil, sludges, and ground water at the site.  The  primary contaminants of concern affecting the
ground water, surface water, soil, and sediments are VOCs including benzene, toluene, TCE, and xylenes,
other organics including fenac, phenols, and  PAHs, and metals including lead,  chromium, and arsenic.

      The selected remedial  action for this  site  includes:   excavation of approximately 252,000 yd  of
contaminated sludge, soil, and  sediments, followed by  treatment in an onsite mobile rotary kiln incinerator,
backfilling  (possibly using the  incinerator  ash  as  backfill material) and installation of a  vegetative cover;
design and construction of an  onsite wastewater biological activated carbon  treatment  plant with pump and
treatment  of the surface water, ground water, storm water, and aqueous wastes from the leachate  lagoon at
the treatment plant, followed by  discharge to a local stream or POTW; and ground water monitoring. The
estimated present worth cost for this remedial action is  $97,363,000 with an average annual O&M of $787,000.

PERFORMANCE STANDARDS  OR GOALS:  Ground water cleanup goals will attain an overall risk level
of 10  by  treatment of the ground  water to  MCLs or MCLGs. Discharge  level of treated water  will meet
local POTW and  NPDES requirements. Individual contaminant goals were  not specified.

INSTITUTIONAL CONTROLS:  Not applicable.
                                              B-49

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                       FIKE CHEMICAL, WV
                                        First Remedial Action
                                         September 29, 1988
ROD ABSTRACT
      The Fike Chemical site is  an approximately  11-acre site  located in the Nitro Industrial  Complex,
Nitro, West Virginia, on  the  flood  plain of the Kanawha  River, which is 2,200 feet to  the  west.   The
population within a  10-mile radius of the site is estimated to be 25,000.  The site consists of the Fike
operations property and the Cooperative Sewage Treatment, Inc. (CST) property, which is a joint venture
between Fike (now Artel  Chemicals,  Inc.) and Coastal Tank Lines,  Inc.  The  Fike  plant property was an
active chemical manufacturing plant from 1968  to June 1988.  During Pike's operation, over 60 different
chemicals  were produced,  all  by batch reaction on an  as-needed basis.  Other  site activities leading to
contamination include onsite disposal of hazardous wastes through drum burial and unlined  surface lagoons,
and tank storage of various chemical stock, products, and wastes.  The CST property, which is adjacent to
the Fike property to the northwest, consists of a series of basins, treatment tanks, and  sludge drying beds,
which are designed to treat plant surface  runoff and process wastewater delivered from Fike Chemical via
separate sewer systems.  The treated water is discharged into the  Kanawha River.  The CST property has a
long history of enforcement  activity  resulting  from  violations of  their NPDES permit  and various
noncompliance  issues  under  RCRA,  leading  to  termination  of  interim  status  in November  1985.
Approximately 300 bulk storage tanks are located onsite, containing acids, bases, flammables, and cyanides.
A minimum of 2,000 surface  drums are onsite in  uncontrolled storage  facilities.   Approximately 8,000
laboratory containers of known and unknown  contents are  at the site.  Wastes buried onsite include 1,000
drums and an undetermined number of additional laboratory containers. Approximately 100,000 pounds of
metallic sodium is  contained in 300 of the drums onsite. A pressurized tank of methyl mercaptan contains
approximately 9,000 gallons. This remedial action will reduce the imminent hazards currently present onsite.
Contaminated soil and  ground water will be addressed in a  subsequent remedial action.  The primary
contaminants of concern affecting the soil, ground water, and surface water are organics including PCBs and
methyl mercaptan, inorganics including cyanide, asbestos, and acids, and metals.

      The selected remedial action for this site includes:  removal and offsite treatment through incineration
and offsite disposal of the tank containing methyl mercaptan;  offsite treatment and disposal  of  drums of
metallic sodium; removal, bulking, and offsite treatment and disposal of drums on the ground surface and of
the materials found in various tanks, lines, and vessels (through incineration, offsite ion exchange, or chemical
oxidation  and stabilization or fixation, depending on drum/tank contents); lab-packing and offsite disposal of
laboratory containers or treatment through offsite incineration; drainage and stabilization of lagoons  and
treatment  of the drained  liquids  with discharge of treated liquids to Kanawha River; excavation, bulking,
storage, and offsite disposal of  buried drums; stabilization and/or removal and disposal of asbestos-containing
insulation  materials found in process lines; and removal and disposal of cyanides.   The estimated present
worth cost for this remedial action is $8,000,000 with no associated O&M costs.

PERFORMANCE STANDARDS OR GOALS:   This remedial action  is designed to reduce or eliminate the
most threatening hazards to human  health and the environment.  The ROD individual goals  were not
specified.   Lagoon liquids  will  be treated and  disposed of in accordance with the NPDES permit  issued by
the State.

INSTITUTIONAL  CONTROLS:  Not applicable.
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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     HENDERSON ROAD, PA
                                        First Remedial Action
                                           March 30,  1988
ROD ABSTRACT
      The Henderson Road site is an active waste  facility situated on 7.6 acres of land in Upper Merion
Township, Pennsylvania.  The land in the vicinity of the site is zoned for light industrial, heavy industrial, and
residential use.  The site is approximately 2,000 feet south and upgradient of the Upper Merion Reservoir
(UMR), where ground water is part of a public  water supply serving 228,000 customers. A water supply well
350 feet southeast and upgradient of the site serves 15 employees of a lumber company. The site area is also
characterized by sinkholes resulting from dissolution  and subsequent collapse  of the dolomite and limestone
bedrock. The O'Hara  Sanitation Company (OSL) presently occupies the site  with several automobile repair
shops and  a drilling contractor.  The OSL presently  conducts  onsite waste storage and  waste recycling
operations. An anonymous phone call to the Pennsylvania Department of Environmental Resources (PADER)
in 1977 stated that ABM Disposal Service Company transported and then injected industrial waste into a well
located  inside the OSL maintenance garage.  Limited  information is available on the types or volumes of
materials disposed of before PADER was notified of injection activities at the site.  Results of PADER and
EPA sampling conducted between 1977 and 1981, and ground water monitoring conducted in 1986 revealed
the presence of organic and  VOC contamination both on  and  offsite.  Of the 35 chemicals of concern
identified at the site,  fifteen were found in UMR in 1986.   Certain  site-related chemicals  also have been
detected between the site, UMR, and the adjacent water supply well.  Additionally, the site is located in an
area of regional  ground water contamination. Studies also indicate that the central plume of contamination
from the site has not yet reached the UMR, based on  an estimated travel time for  ground water from the
site  to  reach UMR.   However, onsite ground water  is  still highly contaminated  and  the  extent  of
contamination in the rocks and fractures in the  unsaturated bedrock has not been  fully characterized.  A
potential might exist for increased offsite loading to the ground water.  The primary contaminants of concern
include VOCs and organics.

      The selected remedial action for this  site includes:   installation of onsite  and  downgradient (if
necessary)  ground water recovery wells  and treatment using air stripping with  probable  discharge to an
adjacent stream  and possible  discharge of a portion of the treated  ground  water onto an area near  the
injection well as part of the unsaturated zone treatment (soil flushing); closure of the injection well; excavation
of contaminated oil pit sediments and removal of significant waste, if feasible, directly out of the injection
well; installation, operation, and maintenance of a carbon adsorption water treatment system at an affected
offsite active well; deed restrictions affecting ground water usage; ground water monitoring; collection and
evaluation of data during RD/RA phase  for possible pilot testing of in-situ volatilization (ISV) of VOCs or
another appropriate treatment  technology in the unsaturated zone; and  periodic reevaluation of cleanup goals.
The estimated present  worth cost for this remedial action ranges  from $5,500,000 (without ISV, unsaturated
zone treatment, or downgradient pump and treatment) and $12,200,000 (with ISV).

PERFORMANCE STANDARDS OR GOALS:  Ground water cleanup  will attain a 7 x 10"4 cancer risk level.
Complete  aquifer restoration  is not  considered feasible because of background contamination.  Should
background contamination increase or decrease, the risk  level will also  change.  Individual cleanup goals were
provided for 46 chemicals.  Some goals include:  PCE 6.9 ug/1 (derived from  EPA Superfund Public Health
Evaluation  Manual), TCE 25.8 ug/1 (ACL based on background levels), toluene 2,000  ug/1 (MCLG), benzene
5.52 ug/1 (ACL based  on background levels), chromium 50.0 ug/1 (MCL), and lead 20.0 ug/1  (MCLG).

INSTITUTIONAL CONTROLS:  Deed restrictions will be implemented to limit or prohibit ground water
usage on properties affected by  the injection well.
                                               B-51

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                         KIMBERTON, PA
                                        First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The Kimberton site is located in the northeastern portion of Chester County, Pennsylvania, near the
Philadelphia metropolitan area.  The site encompasses the Monsey Products Company property and adjacent
properties within the surrounding Village of Kimberton. Several buried lagoons are located on the site. The
lagoons are in close proximity to numerous private water supply wells and less than one mile from French
Creek, which is used for public recreation and fishing.  The site had two successive owners before Monsey
Products purchased it in 1968. All owners were involved in industrial production.  One owner, Ciba Products
Company, a predecessor of CIBA-GEIGY, operated eight lagoons at the site during its period of ownership
from  1947  to 1959.  The lagoons received various residues from the  manufacturing operations at the time.
In August 1981, VOCs were  first detected during routine water quality testing of a private well on Monsey
property.  EPA's subsequent  investigation in early 1982 indicated that soil, ground water, and surface water
were  contaminated by VOCs including DCE, TCE,  and vinyl chloride.   The lagoons were  identified as a
source of contamination, and subsequently,  approximately 2,050 yd  of contaminated soil from three former
lagoon areas were  excavated and disposed of offsite in September 1984 as part of a site remedial action plan.
The excavations were backfilled, regraded, and revegetated.  Furthermore, in December 1986, CIBA-GEIGY
and Monsey Products provided 25 residential and commerical locations with an alternate source of drinking
and contact water.  Currently, sampling and analysis has or currently is being performed in other lagoon areas
to evaluate their potential  as  sources of ground water contamination.  This remedial action was designed to
address the health  risk to those residents who may continue to use contaminated private wells. A subsequent
ROD will  address  other sources  of contamination  as  well as additional ground water  remediation.  The
primary contaminants of concern affecting the ground water are VOCs including DCE, TCE, and vinyl
chloride.

      The selected remedial action for this site includes:  continued  provision of an alternate water supply
— either by treating impacted residential and commerical wells by filtration using granular activated carbon
adsorption  or by providing below-grade storage tanks for  all water  needs (contact and  drinking use);  and
continued monitoring of impacted  wells.   The  estimated  present worth cost for this  remedial  action  is
$3,850,000 with estimated annual O&M costs of $250,000 to $300,000.

PERFORMANCE STANDARDS OR GOALS: Ground water treatment will attain a 10"6 risk level for VOCs.
The use of granular activated carbon filters in impacted offsite wells has reduced the contaminants of concern
to non-detectable levels.

INSTITUTIONAL  CONTROLS:  Not applicable.
                                               B-52

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                      Progress  Toward Implementing Superfund:  Fiscal Year 1988
                                     LA. CLARKE & SON, VA
                                        First Remedial Action
                                            March 31, 1988
ROD ABSTRACT
       The 40-acre LA. Clarke site is located in Spotsylvania County, Virginia.  Wood preserving operations
began at LA. Clarke & Son, Inc. in June 1937 and have continued to date with only one inactive period, from
April 1979 to June 1980.  During the past 50 years, creosote contaminated soil  and sediments resulted from
facility operations spills, waste streams  entering the drainage ditches, and onsite  disposal.  Historical aerial
photography  indicates that from at least 1953 through  1974 wastewater was disposed into two concrete-lined
pits. An area located north of the process facility also  received wastes.  Overflow  from the concrete pits was
stored hi an earthen pit.  Excess water was discharged to drainage ditches and sprayed on the ground around
the storage yard  to control dust.  Aerial photography identified four additional waste water pits which date
back to 1937. These four pits were filled in by 1979. In 1975, LA. Clarke &  Son, Inc. was issued a National
Pollution Discharge Elimination System  (NPDES) permit for outfalls from two onsite drainage ditches.  These
permits are still in effect.  Phenol is the  only toxic contaminant regulated by the permit.  In 1980, LA. Clarke
& Son, Inc. was classified under RCRA as  a treater of hazardous waste due to the presence of a wastewater
impoundment lagoon.  As  part of a State-mandated remedial action  in 1982,  approximately 1,400 yd  of soil
was excavated  from  the  processing area to create  a RCRA-regulated soU waste  pile.   The  primary
contaminants of concern affecting both  the soil and sediments  (total volume  of 119,00 yd )  are constituents
of creosote including PNAs and benzene.

       The selected remedial action for this site includes:  in-situ soil  flushing of subsurface soil underlying
the process buildings followed by in-situ biodegradation in the  creosote layer area; biological degradation of
bottom sediments in  the lagoon;  onsite landfarming  of excavated surface soil, sediments, and  subsurface
wetland soil; excavation,  dredging, and  onsite consolidation of contaminated sediments, subsurface wetland
soil, buried pit  materials, and surface soil not  remediated via in-situ  flushing; erosion/sedimentation control;
backfilling excavated areas with treated soil  and sediment; and ground water  monitoring.   The estimated
capital cost  for this remedial  action is $21,080,000 with present worth  O&M of $33,900.  Should it be
determined that the onsite process building requires removal, landfarming/biodegradation may be implemented
at an added  capital cost  of $910,900.

PERFORMANCE STANDARDS  OR GOALS:  To achieve protection of the shallow aquifer for drinking
water purposes, target cleanup levels for subsurface soil include PNAs 10.3 mg/kg and benzene 94.03  mg/kg.
These  levels  correspond to a 10   site risk level and a 10"   risk at the site boundary. These levels also will
protect aquatic life in surface water.

INSTITUTIONAL CONTROLS:  Insititutional controls necessary to maintain  the site will be developed after
completion of the remedial action.
                                               B-53

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                 MIDDLETOWN AIR FIELD, PA
                                        First Operable Unit
                                        December 31, 1987
ROD ABSTRACT
      The Middletown Air Field site covers what is now the Harrisburg International Airport (HIA), located
between the town of Middletown and Nighspire, Dauphin County, Pennsylvania. The airport is owned and
operated by the Commonwealth of Pennsylvania Department of Transportation. The area  surrounding the
base is characterized as mixed residential/industrial.  Between 1898 and 1962, the property was owned by the
U.S. Government  and used by the military.  HIA and several  other entities occupy what was referred to as
the Olmsted Air Force Base. In March 1983, TCA contamination caused six of the ten onsite production
wells  supplying HIA  to be  taken  out of service.   Studies  initiated under the Department of Defense
Installation Restoration Program indicate that  while  ground  water contamination  due to  volatile organic
compounds  exists,  the  exact  source(s)  of  contamination  cannot be  clearly defined.   Ground  water
contamination may result from one  or more, possibly current, sources in the "industrial area". To date, HIA
has been able to temporarily meet the water requirements of the facility by taking the most contaminated well
off-line  as a potable water  source, and by blending potable water from a  number of wells.   The most
prevalent contaminants of concern affecting the ground water  are VOCs including TCE and PCE.

      The selected remedial action for this site includes:  provision of a potable water supply; construction
of a central  treatment plant; ground  water  pump and treatment using air stripping; and ground  water
monitoring.  The estimated capital cost for this remedial action is $3,750,000 with annual O&M of $160,000.

PERFORMANCE STANDARDS OR GOALS:  Ground water cleanup levels will  meet a  cumulative 10"6
cancer risk level for PCE  1.0 ug/1, and MCLs for TCE 5.0  ug/1 and benzene 5.0 ug/1.   An MCLG was
established for toluene 2,000 ug/1.

INSTITUTIONAL CONTROLS:  Not applicable.
                                              B-54

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    NEW CASTLE STEEL, DE
                                    First Remedial Action - Final
                                           March  31, 1988
ROD ABSTRACT
      The New Castle Steel site  (NCS) is a 3-acre disposal dump, located in New Castle, Delaware.  The
site is divided into two parts by a city drainage channel.  One portion of the site, the inactive disposal area,
occupies  1.3 acres, and the active area occupies 1.7  acres.  Since  operations began  in  1907, solid waste
generated by the Deemer Steel Company (DSC), located immediately across the NCS site, was piled and
periodically spread over the surface of the disposal areas.  The waste consisted primarily of black sand which
may contain small quantities of bentonite and corn flour.  Approximately, 1,800 yd3 (2,430) tons of black
sand were generated each year. Other waste materials were sent to the disposal areas and mixed with black
sand. These materials included: slag, coke, iron  oxide, fine sand dust, and metal scrap. Between 1973 and
1980, electric furnace dust was generated at the rate of 9.6 tons per year.   This dust was  mixed with black
sand and spread over the active waste area.  The  adoption of the Delaware Regulations governing hazardous
waste in November 1980 identified the electric furnace dust and any mixture of this material with solid waste
as a RCRA listed hazardous waste (waste number K061).  EPA subsequently changed the definition of K061,
and none of the waste from DSC operations would qualify as a  listed hazardous waste.  In December 1980,
the electric  furnace dust was found to  be EP-toxic for cadmium,  chromium,  and lead.  A June 1984
hydrogeological study reported the thickness of wastes in the fill section ranged from 8 to 13 feet, and the
average thickness was approximately 10 feet.  Wastes were placed over predominantly unconsolidated marsh
sediments, which are underlain by approximately 50 feet of low-permeability clays.  The uppermost Potomac
aquifer, an important drinking water source,  lies  about 70 feet below the site,  and is  protected by the
low-permeability clays.  An Endangerment Assessment (EA) was prepared  based on the data collected from
the samples in January  1987.   The EPA concluded that  no  significant  risk  to human health and the
environment could be attributed to the site.  Contaminant screening identified five indicator chemicals.  They
include:  arsenic,  cadmium, chromium, lead, and  nickel.

      The selected remedial action for this site  is  no further action.   EPA will monitor surface wastes for
lead until the site is deleted from  the National Priorities  List (NPL) and closed under the State  closure law.
There is no  capital cost or  O&M associated with this  remedial action.

PERFORMANCE  STANDARDS  OR GOALS:  Concentrations in  ground water of lead, cadmium  and
chromium are below the  levels established as  MCLs under the Safe Drinking Water Act.  Lead detected  in
surface water has exceeded Ambient Water Quality Criteria and may be adversely impacting a localized
wetlands area.  There is no evidence to link the levels of lead in the wetlands to the site.   The higher levels
can be partially attributed to the urban environment and tidal influx from  the river.

INSTITUTIONAL CONTROLS:   Not applicable.
                                              B-55

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                      Progress Toward Implementing Superfund:  Fiscal Year 1988
                               ORDNANCE WORKS DISPOSAL, WV
                                        First Remedial Action
                                           March 31, 1988
ROD ABSTRACT
       The Ordnance Works Disposal site, also known as the Morgantown Ordnance Works, is located one
mile south of Morgantown, West Virginia.  The Monongahela River is adjacent to the site with a fairly steep
cliff separating the river from portions of the site.  Remediation for this first operable unit focuses on the
waste disposal area which consists of an inactive landfill, two former lagoons, and the surrounding impacted
area, and a scraped area of bare soil.  These areas are located within an industrial tract of over 800 acres
of which 670 acres are owned by Morgantown Industrial Park Association, a group of private individuals who
joined together to purchase  the Ordnance Works property in  1982.  Prior to this, the  site was owned by
numerous companies and used for a variety of chemical production operations.  The landfill covers a surface
area of approximately  1.6 acres.  The landfill was reportedly used from 1942 until  1962, for the disposal of
various solid chemical wastes. Waste materials identified included:  construction debris, slag, ash, and catalyst
pillets.  Arsenic and carcinogenic PAHs  (CPAHs) were  detected in the soils at  concentrations exceeding
risk-based cleanup levels.  The former lagoon and the surrounding area, located adjacent  to the landfill, cover
a surface area of 3 to  4  acres.   This area is relatively flat  with a  cinder-like surface layer  and sparse
vegetation.  Metal plating wastes  were placed in the  lagoon between 1970  and 1976.   The  lagoons were
excavated in 1981  by the responsible party, and the contents were disposed of offsite.  The metals present
in the soil are currently below the recommended cleanup levels.   CPAHs  have  been  identified  at levels
exceeding cleanup  standards in the area adjacent to  the lagoons.  An  oily, stained cinder  material  was
observed in areas where CPAHs were  detected.  The scraped area, carving a  surface area of approximately
162 acres, was an active  disposal area for solid wastes  from 1942 until  1962.  The waste materials  identified
include:  construction debris, oil-like stained soils, and catalyst pillets.  Currently, arsenic and CPAHs exceed
the proposed cleanup levels.  The primary contaminants of concern' affecting the" soil and sediments include
arsenic and CPAHs.

       The  selected remedial action for this  site includes:   consolidation  of  existing  landfill waste  and
application of a multi-layer RCRA cap; excavation and  onsite incineration of former  lagoons and surrounding
area, scraped  area soil,  and  impacted  stream sediments with onsite disposal of treatment residuals in the
landfill prior to the installation of the cap (assuming the ash is not EP toxic); placement of clean fill in the
excavated area, followed by grading and revegetation; implementation of surface  management techniques for
drainage and sediment control  in  the landfill area; ambient air monitoring; and post-treatment monitoring.
The estimated present worth cost  for this remedial action is $6,718,000.

PERFORMANCE  STANDARDS  OR  GOALS:   Risk-based cleanup  levels  for indicator chemicals  were
developed for arsenic  20 mg/kg,  CPAHs 26 mg/kg and  mercury 175 mg/kg.  A  PCB cleanup level of 5
mg/kg was used based on  EPA cleanup  goals for industrial sites.

INSTITUTIONAL CONTROLS: Land use restrictions  that prohibit intrusive activities in capped areas would
apply to  future site use.
                                                 B-56

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                      PALMERTON ZINC, PA
                                       Second Remedial Action
                                            June 29,  1988
ROD ABSTRACT
      The Palmerton Zinc site is composed of two locations in the Borough of Palmerton, Carbon County,
Pennsylvania.  Smelting operations have been conducted at two locations, a west smelter and an east smelter,
flanking the Town of Palmerton, which is located at  the  confluence of the Lehigh River and Aquashicola
Creek. Approximately 7,000 residents live in Palmerton, many of whom work at  the smelting facility.  Land
use in the  area is industrial, residential, and  agricultural.  The drainage pattern in the site area is toward
Aquashicola Creek, designated a warm water fishery by the  State of Pennsylvania, which flows into Lehigh
River. Smelting operations were conducted in the west plant from 1898 to 1987, and in the east plant from
1911 to present.  The site has had three owners, including the current operator, Zinc Corporation of America,
and  historically  has produced  zinc  and  other metals  for  a variety  of products.   Primary  smelting  of
concentrated zinc sulfide ores, conducted until  December  1980, resulted in the emission of large quantities
of zinc,  lead,  cadmium, and sulfur  dioxide.   This air pollution  caused  defoliation of over 2,000 acres  of
vegetation in the vicinity of the east  smelter.  Between 1898 and 1987 process residue and other plant wastes
(as well as municipal waste until 1970) were  disposed of on Cinder Bank, a 2.5-mile, 2,000-acre waste pile
located behind the east plant at the base of the Blue Mountains.  Cinder  Bank contains approximately 27.5
million tons of leachable metals including lead,  zinc, and cadmium, as well as carbonaceous material.  Large
blocks of residue crack and break off, allowing rapid infiltration of runoff during periods  of rain and snow
melt, resulting in contaminated leachate percolating down to the ground  water  and seeping  out  of Cinder
Bank.  This remedial action addresses Cinder Bank.  Additional areas of contamination as well as ground
water and  surface water contamination will  be addressed in subsequent remedial actions.   The primary
contaminants  of  concern  affecting  the  sediments,  ground water and  surface water  are metals including
cadmium,  lead, and zinc.

      The selected remedial  action for  this  site includes:  slope modification,  capping and application of a
vegetative cover on Cinder Bank; construction of surface water diversion channels; surface water and leachate
collection and treatment using lime-activated filtration lagoons  and/or constructed wetlands; implementation
of an inspection,  monitoring,  and maintenance  plan; and wetlands restoration  measures, if necessary.   The
estimated present worth cost for this remedial action will be in excess of $2,861,800; however, the exact figure
will not be known until agreement is reached on  the extent  of remediation during remedial design.

PERFORMANCE STANDARDS OR GOALS:   Surface water and leachate treatment levels will meet Clean
Water Act requirements and  attain surface water  background levels.   Individual cleanup goals were not
specified.

INSTITUTIONAL CONTROLS: Not applicable.
                                                B-57

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   RHINEHART TIRE FIRE, VA
                                        First Remedial Action
                                            June 30, 1988
ROD ABSTRACT
      The Rhinehart Tire Fire (RTF) site is located in a sparsely populated rural area in Western Frederick
County, Virginia, approximately six miles east of the Town of Winchester.  Between 1972 and 1983, the site
owner,  Mr. Rhinehart, conducted a tire disposal operation which  consisted  of transporting discarded tires
from various locations and storing them on a wooded slope behind his home.  By October 1983, an estimated
five to seven million tires had accumulated and on October 31, 1983, caught  fire. A hot oil produced from
melting and pyrolysis of the tires seeped from the pile of tires into Massey Run.  An undetermined quantity
of oil flowed into Hoque Creek, which is a tributary to the Potomac River system.  EPA's Emergency
Response Team (ERT) installed a catch basin to trap the oil; however, because the high rate of oil and water
seepage threatened to exceed the catch basin storage capacity, a lined 50,000-gallon pond was constructed
immediately downslope  from the burn area.  Approximately 800,000 gallons of oil  product was collected,
removed from the  site, and recycled into fuel oils.  Soon after the fire, diversion structures were built by the
owner of the site under a consent order agreement with EPA. EPA,  through the Army  Corps of Engineers,
conducted a Remedial Investigation (RI) to characterize and define the extent of possible contaminants. The
RI indicated that the precipitation falling on the ash-contaminated area continues to mix with both the solid
residue  and the liquid seepage.   This  remedial action will address the control of contaminated migration
off-site via surface water runoff.  A subsequent  remedial action will address source control at the site.  The
primary contaminants of concern affecting the  ground water, soil, and surface  water are metals including
arsenic and lead.

      The selected remedial  action for this site includes:  -collection of surface water runoff with gravity
settling; collection of shallow ground water  oily seeps, oil-water separation, and transport of water to  a
POTW; construction of berms to increase freeboard on two existing on-site ponds; and implementation of soil
erosion controls.  The estimated present worth cost for this remedial action is $1,332,340 with O&M  costs
of $145,000.

PERFORMANCE  STANDARDS OR GOALS:  The selected  remedial  action will minimize the amount of
offsite contamination migration.  Individual containment goals were not specified.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-58

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                              SOUTHERN MARYLAND WOOD, MD
                                   First Remedial Action - FINAL
                                            June 29, 1988
ROD ABSTRACT
      The Southern Maryland Wood Treating (SMWT) site is located in Hollywood, St.  Mary's County,
Maryland.  The site is situated within a wetland area in a  drainage divide such  that runoff from the site
discharges into Brooks Run and Mclntosh Run  tributaries, which flow into the Potomac River.   The area
surrounding the site is predominantly used for agricultural and residential purposes.  From 1965 to 1975,
SMWT  operated as a pressure treatment facility for wood preservation.  Currently, part of the  site is being
used as  a retail outlet for pretreated lumber and crab traps.  The waste generated  at the site included retort
and cylinder sludges, process wastes, and material spillage. These wastes were in six onsite unlined lagoons.
An onsite freshwater pond became contaminated during the facilities active and inactive periods with VOCs,
polynuclear aromatics (PNAs), and base/neutral extractables due to contaminated  ground water and surface
runoff.  Cleanup actions were initiated in 1982 following legal actions by the Maryland Department of Health
and Mental Hygiene.  Liquids removed from the six lagoons were spray irrigated onto  the nearby woods.
The six  lagoons were excavated, backfilled, and graded, and the freshwater pond was partially excavated. The
excavated sludges were mixed with composited sludge and topsoil, and spread in a level treatment area located
on the property. The primary contaminants of concern affecting the onsite ground water, soil, surface water,
sediments, and debris include:  VOCs, PNA, and base/neutral  acid extractables.

      The selected remedial action for this site includes:  excavation/dredging  of soils,  sediments, tank
liquids and cement and treatment using onsite  incineration with onsite disposal of non-hazardous residual
ash, backfilling, regrading, and revegetating, where necessary; installation of a slurry wall; dewatering of the
slurry wall area by a ground water and surface water pumping system, and treatment using activated carbon
adsorption or hydrogen peroxide and irradiation with discharge to the onsite pond;  installation of a geotextile
silt fence, sedimentation basins, and/or  diversion; and  ground  water, surface water, environmental, organic
vapor, and dust monitoring.

PERFORMANCE STANDARDS OR GOALS: All media will attain the cleanup  goal for carcinogenic PNAs
(CPNAs) of 22 ppm based on the maximum lifetime  cancer risk.  These goals  were established for  onsite
future residents. The ash residue is expected to meet Best Demonstrated Available Technology (BDAT).

INSTITUTIONAL  CONTROLS: Not applicable.
                                                B-59

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                       TYSON'S DUMP, PA
                                       First Remedial Action
                                          March 31, 1988
ROD ABSTRACT
      Tyson's Dump, a four-acre abandoned septic and chemical waste disposal site, is  located in Upper
Merion Township, Montgomery County, Pennsylvania.  Several formerly unlined lagoons were used  to store
various industrial, municipal, and chemical wastes.  Spills and overflows reportedly occurred during the period
of operation, thus allowing for the dispersal of wastes throughout the site.  Surface water runoff and seeps
contributed to offsite migration of the wastes toward the Schuylkill River.  The site is bordered on two sides
by unnamed tributaries to the river.   When  the Pennsylvania Department  of Environmental Resources
(PADER) ordered two dumps closed in 1973, the owner of the land, General Devices Inc., removed some
ponded water but did not arrange for the removal of contaminated soils. Immediate removal measures were
initiated in January  1983, following an anonymous citizen complaint about conditions  at the site.  These
measures  included:   construction of a leachate collection and treatment system,  installation  of drainage
controls and a site cover, and fencing of the lagoon area.  In December 1984, EPA issued an operable unit
ROD for the onsite area.  Remedial actions selected in the ROD include excavation and offsite disposal of
contaminated soils and sediments and upgrading the existing air strips to treat leachate, shallow ground water
and surface run-on.  EPA began the  remedial  design phase  for this selected alternative in January 1985.
In the fall of 1985, Ciba-Geigy  Corporation (CGC) agreed to conduct a further investigation of the offsite
area.   In November 1986, CGC  initiated an  onsite pilot study using  an innovative vacuum extraction
technology process.   In June and July 1987, four responsible parties,  CGC, Smith-Kline Beckman, Wyeth
Laboratories and Essex Group submitted an alternative proposal to EPA for the first operable unit cleanup.
This proposal incorporated the results of  the vacuum extraction process  for  remediating lagoon soils.   In
September 1987, after close review of the technology, EPA decided to recommend a ROD  change to include
vacuum extraction. This new alternative was not available when the original Feasibility Study  was conducted
prior to the  1984 ROD.  In addition, CGC's investigation discovered that most of the contamination from the
lagoon areas had migrated into the bedrock and excavation would not remove all the contaminants from the
area underlying the site.  The primary contaminants of concern are  VOCs. The four indicator  compounds
include benzene, trichloroethene, tetrachloroethene, and 1,2,3-trichloropropane.

      The amended remedial action  for  this site includes:   in-situ treatment  of soils and  bedrock using
vacuum extraction; treatment of the vacuum-extracted water using the onsite leachate water treatment system;
installation of a  soil cover following treatment; and ground water monitoring.  The estimated present worth
cost for this remedial action is $10,200,000.

PERFORMANCE STANDARDS OR  GOALS:  Vacuum extraction will  cleanup  a 20 to 40  foot  radius.
Cleanup levels were developed using health-based acceptable intake levels and hypothetical exposure scenarios.
The scenario producing the most stringent  cleanup requirements was selected as the cleanup goal.  Individual
cleanup goals were listed for 45 contaminants.  Cleanup levels  for indicator compounds include:   benzene 50
ug/kg, trichloroethene 50 ug/kg, tetrachloroethene 50 ug/kg, and 1,2,3-trichloropropane 50 ug/kg.

INSTITUTIONAL CONTROLS: Not  specified.
                                                B-60

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                     VOORTMAN FARM, PA
                                    First Remedial Action - Final
                                           June 30, 1988
ROD ABSTRACT
      The 43-acre Voortman Farm site is located in Upper Salucon Township, Lehigh County, Pennsylvania.
The site consists of a sinkhole that contained empty battery casings disposed of in late 1979 and early 1980.
Citizen complaints in 1980 prompted the prohibition of dumping and  subsequent  site investigation.   In
September 1986, the battery casings in the sinkhole caught on fire. Since the battery casings were burning
underground, attempts to extinguish the fire remained unsuccessful. In October 1986, access was gained to
the burning wastes, which  were then excavated and extinguished.  Additional wastes  and residues were
excavated  from the sink hole and disposed of offsite.  The collapse of the sinkhole walls has formed a natural
cap.   There does not appear to be any leaching from  any residual metals, contaminated soils, or battery
casings present.

      The selected remedial action for this site is a no further action with continued ground water monitoring
for five years.  The estimated present worth cost for this remedial action is  $26,000 with annual  O&M of
$6,860.

PERFORMANCE STANDARDS  OR GOALS:  Currently, the ground water does not violate drinking water
standards.  No location-specific or action-specific ARARs are applicable to this alternative.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-61

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                      Progress Toward Implementing Superfund:  Fiscal Year 1988
                                WEST VIRGINIA ORDNANCE, WV
                                   Second Remedial Action - Final
                                         September 30, ,1988
ROD ABSTRACT
      The West Virginia Ordnance (WVO) site covers  approximately 8,323 acres in Mason County, West
Virginia.  It is located on the east bank of the Ohio River.  Almost one-third of the site is occupied by a
2,788-acre wildlife station containing more than 30 shallow ponds created to promote a wetland/terrestrial
habitat for various wildlife species.  Established in 1942, the WVO plant manufactured explosives, specifically
TNT, from toluene.  General Chemical  Defense Corporation of New York operated the plant until 1945.
Red and yellow water (liquid wastes) were produced during the TNT manufacturing process. Yellow water
was discharged to the Mill Creek drainage system, which eventually drains into the Ohio River; red water was
discharged directly to the Ohio River through a pipe located about one foot offshore. Retention ponds were
constructed to regulate the discharge of red and yellow water to the river.  TNT and associated by-products
were burned  onsite.  In May 1981, ranger officials observed a seep of red water adjacent  to a pond located
on  the  wildlife station.   Upon  examination,  ground water  discharging to  this pond was  found  to be
contaminated by di- and trinitrotoluenes  and phenol.  Localized  contamination of the shallow ground water
and discharge to surface water have been documented in the vicinity of the TNT manufacturing area, the
burning grounds, sediments of surface water receiving contamination, and former wastewater storage lagoons.
Evidence also indicates that soils  of the industrial area, process facilities, and industrial  wastewater facilities
are contaminated by TNT and associated by-products (nitroaromatics).  Based on the hydrogeologic setting
of WVO, there is potential for contamination to migrate  via surface water and/or ground water pathways to
deeper layers of an underlying potable aquifer, or to the Ohio River.   Contaminant migration is possible
toward  the City of Point  Pleasant and  Camp  Conlay  community  potable water  supplies.   The primary
contaminants of concern affecting  the soil, sediments, and ground water are nitroaromatics and lead.

      The selected remedial  action for this site  addresses three distinct areas  of contamination.   These
remedies include:  Area 1 - purchase of contaminated land and control of land use, placing a soil cover over
the contaminated area, and incorporating the area into the existing wildlife preserve; ground water pump and
treatment to  nitroaromatics criteria with  discharge to surface water; monitoring discharge  from the ground
water treatment system to ensure compliance  with the  stream  standards;  and  periodically inspecting  and
maintaining the soil cover in a stable condition. Area 2  - relocating ponds  1 and 2, filling them with clean
material and  covering them with  a soil and clay cap;  ground  water pump and treatment to nitroaromatics
criteria  with  discharge  to  surface water;  and  monitoring effluent  from the treatment  system  to ensure
compliance with surface water  criteria.  Area 3 - installing a soil cover over the West Well Area and the seep
area; ground water  pump and treatment to nitroaromatics criteria with discharge to surface water; monitoring
effluent from the treatment system  to ensure compliance with surface water criteria; and periodically inspecting
and maintaining the soil cover in a stable condition.  The estimated present worth for  this remedial  action
is $3,365,000, with estimated O&M cost of $216,500.

PERFORMANCE STANDARDS OR GOALS: West Virginia ground water protection standards permit ACLs
if these  levels will not pose a substantial  present or potential hazard to health or  the environment.  Ground
water cleanup levels were based on available chemical-specific standards, or a 10  cancer risk.  Concentration
limits for treated  ground water  in  Areas 1 and 2 include:    TNT 50  ug/1, dinitrobenzene  14 ug/1,
trinitrobenzene 200 ug/1, 2,4-DNT 0.11 ug/1, and 2,6-DNT 0.022 ug/1. The criteria for Area 3 ground water
include: TNT 4.6 mg/1; dinitrobenzene 12 mg/1; trinitrobenzene 6.2 mg/1; 2,4-DNT 0.26 mg/1,  and 2,6-DNT
0.052 mg/1.

INSTITUTIONAL CONTROLS:  The purchase  of Area 1 and incorporating it as part of  the wildlife preserve
will prohibit development of the lands  for residential  or  industrial use.
                                                 B-62

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                          WESTLINE, PA
                                      Second Remedial Action
                                           June 29, 1988
ROD ABSTRACT
      The Westline site, located in the town of Westline, McKean County, Pennsylvania, is a 40-acre tract
of land formerly used as a lumber  processing facility.  Between 1901 and 1952, the onsite chemical plant
converted lumber into charcoal, methanol, and acetic acid.  In 1952, the plant was closed due to equipment
deterioration and declining profits.  Waste tars containing high levels  of polynuclear aromatic hydrocarbons
(PAHs) and various phenolic compounds were left onsite.  An Emergency Removal Action was implemented
in 1983 to remove the largest tar deposit, and a Record of Decision was signed in July, 1986 to address the
excavation and offsite incineration of remaining tar deposits and contaminated soil.  This second operable unit
addresses potential ground water contamination.   In  1985 high levels  of benzene were found in two  onsite
monitoring wells.  Additional tests indicated the presence of toluene, trichloroethane, phenol, and other VOCs;
however, benzene was the only contaminant that exceeded Federal Maximum  Contaminant Levels (MCLs)
of 5 ug/1, and is, therefore, the primary contaminant of concern.

      The selected remedial action for the ground water operable unit at the Westline site is no further
action. Since drinking water for the town of Westline is obtained from small streams upgradient of the site
and all contaminants except benzene are below Federal MCLs,  EPA has determined that no significant risk
to public health and the environment exists.  Ground  water will be  monitored to ensure  effectiveness of
natural attenuation, and institutional controls will be implemented  to  prevent  construction of new drinking
water wells in the contaminated area. There are no capital costs associated with the remedy, and O&M costs
for monitoring were not specified.

PERFORMANCE STANDARDS OR GOALS:  Natural attenuation  can meet the MCL for benzene 5.0 ug/1
within a 5  to 10 year period.  The remedy  meets the 8.93 x 10'5 increased cancer risk level.  Additionally,
Water Quality Criteria and standards have not been exceeded.

INSTITUTIONAL CONTROLS: Restrictions will be implemented to prevent drilling of drinking water wells
onsite.
                                                B-63

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                      Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     WILDCAT LANDFILL, DE
                                        First Remedial Action
                                            June 29, 1988
ROD ABSTRACT
       The Wildcat Landfill site  is located  2.5 miles southeast  of Dover in Kent  County,  Delaware.  The
44-acre site is bordered to the north and east by the St. Jones River and its associated wetlands, and to the
south and west by residential and commercial development. A pond, created by construction of the landfill,
is  located directly adjacent to the site along the northwestern edge.   The  pond is the subject of a second
operable unit for the site. Portions of the site lie within the 100-year floodplain of the St. Jones River.  The
site was operated as a permitted sanitary  landfill between 1962 and 1973, accepting both municipal and
industrial wastes. Industrial wastes suspected to have been disposed of include latex waste and paint sludges.
Throughout its 11 years of operation, the facility routinely violated operating  and other permits issued  by
regulating agencies. EPA began investigating the site in 1982. Typical wastes encountered at the site included
municipal refuse latex in strips and sheets; scattered crushed, empty, or intact drums; and manufactured plastic
items.  Much of the waste is located on low-lying wetland  sediments; however, the area to the southwest was
excavated and backfilled with wastes.  Consequently, in that area of the landfill, wastes are  in direct contact
with the surficial sand aquifer.  The primary contaminants of concern affecting the soil and ground water are
VOCs including benzene, other organics including PCBs,  and  metals including arsenic and  lead.

       The selected remedial  action  for  this site  includes:    grading, installation  of a  soil  cover, and
revegetation of onsite direct contact risk areas; removal  and offsite disposal of drums containing wastes  by
landfilling (if not hazardous) or incineration (if hazardous); replacement of two domestic wells  adjacent to
the site; institutional  controls including well and  land use restrictions; and groundwater monitoring.  The
estimated present worth cost for  this remedial action is $5,400,000.

PERFORMANCE STANDARDS OR GOALS:  The performance goal of this remedial action is to eliminate
the existing direct contact risks posed by the landfill through institutional controls and  to control contaminant
migration.  Individual contaminant goals are not applicable.

INSTITUTIONAL CONTROLS:  Well restrictions on installation of all drinking water wells onsite  and in
adjacent offsite areas.   Land use  restrictions on any commercial  or residential  building onsite.
                                                 B-64

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                             AIRCO, KY
                                    First Remedial Action - Final
                                            June 24, 1988
ROD ABSTRACT
      The Airco site is  a 2.7-acre industrial waste landfill located outside the zoned area of Calvert  City,
Marshall County, Kentucky.   The site is  situated on the  eastern edge of a heavily industrialized area.  It is
bordered on the west by the B.F. Goodrich (BFG) NPL site,  on the east by undeveloped land and a slough,
on the north by the Tennessee River, and on the south by agricultural land and a State highway.  (The Airco
site and the BFG site were studied as one site for the RI/FS and their remediation will be combined since
they are located adjacent to each other and share a somewhat common history  of use.) Airco began disposing
waste material from their Calvert City plant into the landfill in 1959. By 1971, 18,000 tons of  caustics, acids,
VOCs, zinc, and mercuric acetate and mercuric chloride reportedly were disposed at the site.  The landfill
was unregulated until 1968, when a Solid Waste Disposal Permit was applied for and granted by the Kentucky
Department of Natural Resources and Environmental Protection. Airco's Calvert City plant was sold to Air
Products and Chemicals, Inc. (APC), in  1971.  APC also leased the landfill  from Airco until 1980,  during
which time they disposed of approximately 14,000 tons of coal ash containing low level metal contaminants,
as well as polyvinyl chloride solids, ferric hydroxide sludge, and  construction  waste at the site.  The landfill
was capped and closed in September 1981. The site was placed on the NPL hi September 1984. The primary
contaminants of concern affecting the soil, sediments, and ground water are VOCs including benzene, toluene
and 1,2-dichlorethane, and other organics including PAHs and PCBs.

      The selected remedial action for  this site includes:  excavation and  consolidation of approximately
5,000  yd  of contaminated soil and sediments within the  dikes and around the landfills from both the Airco
and BFG sites, with onsite disposal in the former burn pit  area at the BFG site followed by construction of
an organic vapor recovery system and a RCRA cap over the burn pit; reconstruction of the dikes surrounding
landfills for flood prevention; upgrading  of the landfill caps and installation of  a leachate extraction  system
with onsite treatment of the leachate and offsite discharge to the local river; pump and treatment  at the BFG
plant  site of ground water using  air stripping and biological  treatment or activated carbon adsorption,  and
discharge to the local river; possible treatment  of ground water with an oil/water separator if ground water
contains  significant  oil, and temporary  onsite storage of oil with transport offsite to an oil recycling facility;
access restrictions; and institutional controls to prevent residential development. The estimated present worth
cost for this remedial action  (including all costs related  to the BFG site), is $6,090,000 with present worth
O&M estimated to be $3,130,000.

PERFORMANCE  STANDARDS  OR GOALS:   Ground  water cleanup levels will attain specific ACLs for
the selected indicator chemicals at the site and include EDC (8.5 mg/1), benzene (8.5 mg/1), and TCE  (8.5
mg/1). Contaminated subsurface soil in  the burn pit areas will attain an EDC level of 139 mg/kg, which is
based on the allowable EDC ground water concentration.

INSTITUTIONAL CONTROLS:  Deed restrictions will be implemented to prevent residential development
and installation of drinking water supply  wells.
                                                 B-65

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     ALPHA CHEMICAL, FL
                                    First Remedial Action - Final
                                           May 18,  1988
ROD ABSTRACT
      The Alpha Chemical  site, located  in Kathleen, Florida, consists of over 32 acres that comprise the
Alpha Resins Corporation (ARC), a facility of the Alpha Chemical Corporation.  Surface water from the
site drains into a swampy, low-lying wetland area.  Karst topography is evidenced by sinkholes  in the area.
The facility has produced unsaturated polyester resin for fiberglass manufacturers since  1967.  A waste
stream,  referred to as the "water of reaction", is produced  as  a by-product of polyester  resin formation.
This waste stream is composed primarily of water containing small amounts of organics.  ARC obtained a
State permit in 1967 to place this waste stream in two unlined surface impoundments.  The permit allowed
for the  ponds to act  as percolation basins, allowing for  the natural biodegradation of the organics. The
percolation ponds have not been used since 1976. At that time, a thermal oxidizer was installed to incinerate
the waste  stream rather than place it in the percolation ponds. After switching to incineration, Pond 4 dried
up.  It was then used for one year as a solid waste landfill by ARC and its employees.  In 1977, the landfill
was covered with two feet of native soil. In 1982, ARC contacted the Florida Department of Environmental
Regulations (DER) to obtain a permit to line  Pond 3 with concrete for caustic wash water disposal.  As a
condition of the permit, DER required ARC to install ground water monitoring wells.  In April, 1983, a DER
ground water assessment report indicated  industrial impacts on the surficial aquifer.  Further soil and ground
water sampling investigation did not  reveal  a  definable plume of  contamination.  Of the  23  organic
constituents identified in the ground water, ethylbenzene was found to be the most frequently detected, having
a high concentration of contamination.

      The selected remedial action for this site includes placing  a low permeable cap over the unlined pond
area, and long-term ground water and surface water monitoring.  The estimated capital cost for this remedial
action is $142,400 with present worth O&M of $186,200.

PERFORMANCE STANDARDS OR GOALS:  Recommended AWQC are met for all wells at the property
line and immediately downgradient of all site areas except the unlined pond.  Capping will manage the threat
of future releases from the pond area and meet AWQC downgradient of the unlined pond for:
ethylbenzene 1.4 mg/1 and 1,2-dichloropropane 1.4 mg/1.

INSTITUTIONAL CONTROLS: Not  applicable.
                                                B-66

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                BROWN WOOD PRESERVING, FL
                                    First Remedial Action - Final
                                            April 8, 1988
ROD ABSTRACT
      The 55-acre Brown Wood Preserving site is located approximately two miles west of the City of Live
Oak,  Suwanee  County, Florida.  The site  is located  in karst terrain  in which  sinkholes are a common
geological feature.  The areas surrounding the site are considered rural and light agricultural.  There are
four private wells located along the site periphery that obtain water from an aquifer 20 to 100 feet below the
site.  The public water supply wells for the City  of Live Oak are located less than two miles away.  The
site contains  a  former wood preserving plant facility, which pressure-treated timber products with creosote
and some pentachlorophenol (PCP) between 1948  and  1978.  During this time, several different companies
operated the facility.   In  addition,  the facility was rebuilt  following  a fire in February 1974.  Sludge and
contaminated soils have been identified in the immediate vicinity of the plant site and an upgradient  lagoon.
This three-acre lagoon drains approximately 74-acres and contains  water provided above approximately  3,000
yd3 of creosote sludge and contaminated soil. In addition, small amounts of solidified creosote and PCP are
contained in onsite storage tanks and retorts.  In 1981, EPA was notified by one of the former facility owners
that hazardous  waste may have been handled at  the site.   In July 1982, the Florida Department of
Environmental  Regulation (FDER) inspected the site and  detected a number of organic  compounds. An
action, completed in February 1988, resulted in the  removal  of approximately 200,000 gallons of lagoon water
and 15,000  tons of contaminated lagoon sludge and soil. The primary contaminants of concern affecting the
soil, sediments, sludge, and waste water are creosote constituents  including PAHs.

      The selected remedial action for this site includes:  removal and treatment, if necessary, of lagoon
water with  discharge to 'a  POTW; excavation, treatment, and offsite disposal of approximately 1,500  tons of
the most severely contaminated soil and sludge; onsite biodegradation  of approximately 10,000 tons of the
remaining soils  in a  14-acre treatment area constructed with  a liner  and  an internal drainage and  spray
irrigation system; covering of  the treatment area  with clean  fill after bioremediation; and  ground water
monitoring.  The estimated present worth cost for  this  remedial action  is $2,740,000.

PERFORMANCE STANDARDS OR GOALS:  The soils will be treated to reduce the concentration of total
carcinogenic indicator chemicals to 100 mg/kg throughout the volume of material treated. This level for total
carcinogenic indicator chemicals corresponds to an approximate 1  x 10    soil ingestion risk level.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-67

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                              CELANESE FIBERS OPERATIONS, NC
                                       First Remedial Action
                                          March 23, 1988
ROD ABSTRACT
      The 450-acre Celanese Fiber Operations (CFO) site is occupied by a polyester raw-material production
facility, and is located  in Cleveland County, one mile north of Earl, North Carolina.  The plant  facilities
consist of the plant production area, wastewater treatment area, former waste disposal areas, land farm area
and recreation, and tree farm areas south of the main plant. The plant  began operations in 1960 as Fibers
Industries, Inc., and  manufactured polyester polymer chip and filament yarn using  the chemicals  dimethyl
terephthalate and ethylene glycol.  Celanese  Corporation  bought the facility in 1983.  The  CFO  waste
treatment plant was  constructed in phases  concurrent with the manufacturing plant.  This resulted in the
disposal  of chemical wastes directly into  a drainage ditch  during the  early  years of operation  prior to
completion of the waste treatment plant. Treated  effluent has been  discharged to Buffalo Creek since the
mid-1960s, when CFO completed construction of the treatment plant.   In addition to the discharge from the
wastewater treatment plant,  CFO also discharges alum-treated bandcaster water directly  to Buffalo Creek.
Several areas around the plant have been used for waste disposal, including old burning pits for normal plant
wastes (polyester and trash), a glycol recovery unit sludge burial area, and a former drum storage and staging
area (drums contained solutions that failed to polymerize) excavated and backfilled in the mid-1960s, and two
soak-away ponds formerly containing treated sanitary sewage.  In addition, four areas  of buried waste are
located to the north and outside the main plant perimeter fence: a polymer and fiber landfill, a construction
debris landfill, a 21-acre sludge disposal area, and a drum storage area  which temporarily stored 2,000 to 3,000
drums of waste chemicals and solvents,  including lab packs, from 1970 to  1978.  The drums were  removed
and disposed of offsite by 1978. The primary contaminants of concern affecting the ground water include:
VOCs including benzene and PCE, organics including phenols, and metals including chromium.

      The selected remedial action for this site includes:  ground  water pump and  treatment using  air
stripping, biological treatment,  and carbon adsorption  (if necessary), followed by discharge to the onsite
wastewater treatment plant.  If the  treatment  system  effluent  contains metals,  such  as  chromium,  above
allowable discharge levels, the effluent will  be treated using chemical precipitation.  The  estimated present
worth cost for this remedial action is $2,032,000 with estimated present worth O&M of $1,069,230.

PERFORMANCE STANDARDS OR GOALS:  Ground water cleanup will attain Federal or State MCLs,
whichever are more stringent.   Individual cleanup goals were not specified.

INSTITUTIONAL CONTROL:  Not applicable.
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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                        CHEMTRONICS, NC
                                    First Remedial Action - Final
                                            April 5, 1988
ROD ABSTRACT
      The Chemtronics site,  an active waste  disposal facility, is located  in  a  rural area of Swannanoa,
Buncombe County, North  Carolina.  The  1,027-acre site was  developed as an industrial facility  in  1952.
Several  companies operated the facility prior to its purchase by Chemtronics, Inc. in 1978.  Waste disposal
operations only occurred over  approximately ten acres of the site. Existing records indicate the presence of
twenty-three individual onsite disposal areas (DAs) which are grouped into six discrete areas:  DA-6,  DA-7/8,
DA-9, DA-10/11, DA-23, and the acid pit.  The site can also be divided into  two geographical subsections
referred to as Front  Valley and Gregg Valley.  Disposal practices prior  to  1971  were not well  defined;
however, solid waste materials  and possibly solvents were incinerated in pits dug  in an  area previously referred
to as  the burning ground, and  currently referred to as the acid pit area.  Additionally, chemical wastes were
disposed of in trenches beside this burning ground.  Waste  materials generated in the production of the
chemical  warfare  agent,  3-quinuclidinyl  benzilate (BZ),  and  the  tear  gas agent,  o-chlorobenzylidene
malononitrile (CS), were placed in 55-gallon drums with a neutralizing  solution, and then buried onsite in
trench-type landfills.   From  1971  to  1975,  small volumes of liquid wastes  were disposed of in  onsite
pits/trenches.  Solid wastes, rocket motors, explosive wastes, and other waste types also were burned in the
burning ground area.   From 1975 to 1979, Chemtronics, Inc. constructed pits/trenches, as needed, for the
disposal of spent acid and various organic wastes. These pits/trenches were constructed in the burning ground
area.  In 1980, North  Carolina ordered Chemtronics to discontinue all discharges to  site pits/trenches. The
pits subsequently have been back-filled.  Starting in 1979, Chemtronics  installed  a 500,000 gallon lined lagoon
over an old leaching field for  the biotreatment of waste waters.  The incompatibility  of the liner  with the
brominated wastes introduced  into the lagoon caused the lagoon to  leach its contents.  The bio-lagoon was
reconstructed in August, 1980, with a different liner, and deactivated in  1984.  In September 1984,  the U.S.
Army Toxic and Hazardous Materials Agency sampled two drums at the  surface in DA-10/11.  These drums
were suspected of containing wastes from the production  of BZ.  Although no BZ was found, an immediate
removal of these drums was initiated in January, 1985, due to  heightened public awareness/involvement with
the site. The primary contaminants of concern affecting the soil, sediments, ground water, and surface water
include  VOCs, benzene, PCE,  TCE, organics, -metals,  arsenic, pesticides, and explosives.

      The selected remedial  action for this site  includes: multi-layer  capping  of  DA 6, DA 7/8, DA-9,
DA-10/11, and the  acid pit area with fencing, placement  of a vegetative  cover over the cap, and installation
of a gas collection  ventilation system,  if necessary; treatability studies  for soils associated with DA-23 to
determine the most appropriate soil fixation/stabilization/solidification  process and mixing ratios, followed by
onsite capping; ground water pump and treatment which may include air stripping, carbon adsorption,  or metal
removal with treatment and discharge to be determined during design; sampling of pond water and sediments
and,  if  necessary,  treatment  using  the   ground  water  treatment  system   or  the  selected  soil
treatment/containment process; and  sediment, ground water,  and  surface water monitoring.  The estimated
present  worth cost for this  remedial  action ranges from $6,247,300 to  $8,242,900.

PERFORMANCE STANDARDS OR GOALS: Ground water cleanup levels were provided based on MCLs
and several TBCs.  Some individual goals include: TCE 0.005 mg/1 (MCL), benzene 0.005 mg/1 (MCL), PCE
0.007 mg/1 (RSD), toluene 2.0 mg/I (PMCLG), RDX 0.035 mg/1  (USAIWQC), TNT 0.044 mg/1 (PPLV), lead
0.05 mg/1 (MCL), and chromium 0.05 mg/1 (MCL).  Some individual soil cleanup goals include:  PCBs 10
mg/kg (TSCA), RDX 95 mg/kg (PPLV), TNT 305 mg/kg (PPLV), and CS 43.3 mg/kg (PPLV).

INSTITUTIONAL CONTROLS:  Controls will be implemented; however, none were specified.
                                                B-69

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                          FLOWOOD, MS
                                    First Remedial Action - Final
                                         September 30, 1988
ROD ABSTRACT
      The Flowood  site consists of 225 acres of mostly wetlands and lowlands, is  located in the Town of
Flowood, Rankin County, Mississippi, on the east  side of the Pearl River.  The site includes wastewater
discharge areas and  downstream areas adjacent to two industrial manufacturing facilities.  The immediate
area of the site includes a borrow-pit, a slough or canal used as a discharge area, a flood levee, and a cow
pasture with an area of ponded water.  The site is bordered  to the north and east by various industrial and
commerical operations, while forested areas are located west of the site.  The nearest residence is more than
0.5 mile  south of the  site.  Two  manufacturing facilities have been owned and operated by a series of
companies at the Flowood site  since the 1950s. The northernmost facility manufactured corrugated boxes,
and the southernmost facility produced ceramic tiles through the 1970s, and stoneware  cooking pots from the
mid-1970s to the present. A routine industrial wastewater inspection conducted by the Mississippi Department
of Natural Resources (MDNR) in the fall of 1982 revealed  the unpermitted discharge of hazardous substances
to the onsite canal. Subsequent sampling detected lead contamination in water and sediments from the canal.
The MDNR began an emergency treatment and removal process to address the contaminated wastewater, but
discontinued  the process  when higher  levels of  lead  were  found in  the canal  adjacent to one of the
manufacturing sites.  In 1983, EPA investigations revealed high lead levels in onsite sludges, sediments, and
surface soil.  The primary contaminant affecting the soil and sediments is lead.

      The selected remedial action for this site includes:  excavation and stabilization/solidification  through
chemical fixation of approximately  6,000 yd3 of soil and sediments from all contaminated areas, followed by
placement of the treated material in the excavated slough/lagoon area, capping with clean top soil and seeding
to provide a vegetative cover;  and ground water monitoring.  The estimated present worth cost of this
remedial action is  $2,000,000 with a first year O&M cost  of  $25,000.

PERFORMANCE STANDARDS OR GOALS:  A risk-based  level of 500 mg/kg of lead has been set as the
cleanup goal for soil and sediments.

INSTITUTIONAL CONTROLS. Not applicable.
                                                B-70

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                       GOODRICH, B.F., KY
                                    First Remedial Action - Final
                                            June 24,  1988
ROD ABSTRACT
      The B.F. Goodrich (BFG) site is a one-acre area consisting of a landfill  and waste burn pits and is
located  outside the zoned  area of  Calvert City, Marshall County,  Kentucky.   The  site  is situated on the
eastern  edge of a heavily industrialized area.  It is bordered  on the  east by the Airco NPL site, on the west
by the B.F. Goodrich Company, on the north by the Tennessee River and on the south by a State highway.
(The  BFG site and the Airco  site  were studied as  one site for  the RI/FS and their remediation will be
combined since they are located adjacent to each other and share  a somewhat common history of use.)  The
landfill is a former creek channel made suitable for  landfilling by the construction of dikes on the north and
west sides. The B.F. Goodrich Company used the landfill between 1965 and 1973  to dispose of approximately
54,000 tons of construction-type waste and plant trash.  The company also  operated the burn pit area where
several pits were used to burn approximately 2.6 million gallons of liquid chlorinated organics.  Additionally,
370 yd  of salt-brine  sludge was buried  in an area near the  burn pits.   From 1973  to  1980, excavation dirt
was the only waste disposed at the site.  An  inspection conducted by the  Kentucky Department of Natural
Resources and Environmental Protection in May 1980 revealed a leaching problem along the river side of the
landfill,  and instructed the B. F. Goodrich Company to correct the problem.   The Company resolved the
problem in June 1980. The site was placed on the  NPL in September 1983.  The primary contaminants of
concern  affecting  the soil, sediments,  and  ground water  are  VOCs including  benzene,  toluene, and
1,2-dichlorethane (EDC), and other organics including  PAHs.

      The selected remedial action for this  site includes:  excavation  and consolidation of approximately
5,000 yd  of contaminated  soil  and sediments within the dikes  and around the  landfill from both the BFG
and Airco sites, with onsite disposal in the former burn pit area followed by construction of an organic vapor
recovery system and a RCRA cap over the burn pit; reconstruction of the dikes  surrounding the landfill for
flood prevention; upgrading of  the landfill caps and installation of a leachate extraction  system with onsite
treatment of the leachate and offsite discharge to the local river; pump and treatment at the BFG plant site
of ground water using air stripping and biological treatment or activated carbon adsorption and discharge to
the local  river; possible  treatment  of ground water with an oil/water  separator if ground water contains
significant oil, and temporary onsite storage of oil  with  transport offsite to an  oil  recycling facility; access
restrictions;  and institutional controls to prevent residential development.  The estimated capital cost for this
remedial action (including all costs related to the Airco site) is $6,090,000 with present worth O&M estimated
to be $3,130,000.

PERFORMANCE  STANDARDS OR GOALS:   Ground water cleanup will attain  specific ACLs  for the
selected  indicator chemicals at the site and include EDC (8.5 mg/1), benzene  (8.5 mg/1), and  TCE (8.5
mg/1).  Contaminated subsurface soil in the  burn pit  areas will  attain  EDC level  of  139 mg/kg, which is
based on  the allowable EDC ground water concentration.

INSTITUTIONAL CONTROLS:  Deed restrictions  will be implemented to prevent  residential development
and installation of drinking water supply wells.
                                                B-71

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    INDEPENDENT NAIL, SC
                                  Second Remedial Action - Final
                                         August 30, 1988
ROD ABSTRACT
      The Independent Nail site, occupying 24.6 acres, is located near the town of Beaufort, South Carolina.
The site is surrounded by fields, woodlands, and wetlands.  The United States Fish and Wildlife Service in
1987 indicated that endangered and threatened species may exist in the area of influence of the site, however,
these species have not been confirmed to be inhabiting areas that may be impacted by the operations at the
site.  An estimated 25 residents live within one quarter mile of the site.  The Black & Johnson Company,
previous owners of the  site, manufactured metallic  screws and fasteners.  As  part of the manufacturing
process, the company discharged approximately 33,000 gallons per day of plating  wastewater into an unlined
infiltration  lagoon.  The discharge rate may have been as  high as 75,000 gallons per day. The lagoon was
in use  from approximately  1969 to 1980.   The South Carolina Department of  Health  and Environmental
Control reported that wastewater contained some organic  cleaning solvents and  metals.   In April 1980, the
Black & Johnson Company ceased operation. Two months later, the Independent Nail Company purchased
the plant and currently operates a panneling nail coating process, but does not discharge wastewater to the
lagoon.  The first remedial  action  at this site at this  site addressed the contaminants in  the soil and lagoon
sediments.  This remedial action at this site addresses ground water contamination. The primary contaminants
of concern include chromium, zinc, and cyanide.

      The selected remedial action for this site addressing ground water is a no  action remedy.  The source
control remedial action conducted at the site was determined to have little or no impact on ground water
quality in  the area of the site.  This remedial action  has no costs associated with it.

PERFORMANCE STANDARDS OR GOALS: The endangerment assessment conducted  at the site indicated
that  there was no risk to human health or the environment from ground water.

INSTITUTIONAL CONTROLS:  Not  applicable.
                                               B-72

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     NATIONAL STARCH, NC
                                        First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The National Starch and  Chemical Corporation  (NSCC) site is located  in  Rowan County, North
Carolina, approximately five  miles  south  of  the  city of Salisbury.   The site  consists of 500 acres and is
occupied by the NCSS-owned Cedar Springs  Road Plant which currently manufactures textile finishing and
custom specialty chemicals.  Land use adjacent to the site includes residential and industrial developments
such as:  warehousing operations on the east  site; a farm on the south side; and residential areas bordering
the southwest and north sides.  Ground water in the aquifer beneath the site  is currently used as a source
of drinking water with the closest well being 2,200 feet northeast of the  site. There are 1,539 homes within
a 3-mile  radius of the site that are outside of the city water lines and  potential users of ground water for
drinking  and other domestic purposes.  There  is also potential for  humans  to  directly contact or ingest
contaminated waters through  recreational uses of nearby creeks which receive the surface water runoff from
the trench area.  From 1971 to 1978, NSCC disposed of approximately 350,000 gallons of reaction vessel wash
waters classified as D002 waste (corrosive waste with pH less  than or equal to 2.0) in trenches constructed
in a 5-acre tract of land located behind the plant. The waste consisted predominantly of salt brines, sulfuric
acid solutions,  sulfonating  fats,  and oils and solvents.   The  wastes were disposed  of in several trenches
approximately 250 feet by 9 feet deep, running east/west and north/south. Trenches in this area also received
liquid effluent from the plant where it percolated into the  ground.  After the  percolation rate  substantially
declined, the trenches were backfilled  and seeded. Site monitoring in 1976 and  1977 revealed shallow ground
water contamination adjacent to or within the trench area.  Consequently, the North Carolina  Department
of Natural and Economic Resources requested that NSCC cease onsite waste disposal activities.  Since 1978,
production plant process waters have been pretreated in a facility adjacent to and south of the production area
and  discharged  to the  Salisbury publicly owned treatment  works  (POTW).   The two  main areas  of
contamination identified at the site are the trench area and the wastewater lagoon  area.  This Record of
Decision (ROD) will address remediation of ground water; a subsequent ROD will address soil contamination
and, if necessary, sediment contamination.  The primary contaminants of concern affecting the ground water,
surface water, and sediments  are  VOCs including benzene, TCE, toluene, and  xylenes, and metals including
arsenic and  chromium.

      The selected remedial action for this  site  includes:  installation  of a ground  water interception and
extraction system downgradient of  the source area(s) with pretreatment prior to discharge to the POTW
(pretreatment may include air stripping,  filtration  through an activated carbon filter, metal  removal,  or
treatment through the  company's existing lagoon system which includes presettling  and  surface aeration);
and surface  water  and sediment monitoring.  If the POTW declines to  accept the treated ground water, it
will be discharged to a  local surface  stream  under  an NPDES permit.   The  estimated present worth cost
for this remedial action  is $3,036,000 with annual O&M of $55,000.

PERFORMANCE STANDARDS OR GOALS: Eleven carcinogens and fourteen non-carcinogens have been
identified as chemicals of concern at this site  and have been given cleanup goals.  For both carcinogens and
non-carcinogens, cleanup levels are set at the MCL.  If an MCL is not available, the cleanup goal for a
carcinogen is set at the  limit  of detection  for that substance, or for a non-carcinogen the goal is set at the
RJD or ACI equivalent.  However,  ethyl benzene will meet the proposed MCLG.  Individual cleanup goals
include:  arsenic 10 ug/1 (MCL), benzene 5 mg/1 (MCL),  TCE 5 ug/1  (MCL), chromium 50 ug/1  (MCL),
toluene 2,000 ug/1, and xylenes 350  ug/1.  The State of North Carolina belatedly has identified ground water
cleanup levels more stringent  than those identified previously; however, even if  EPA finds these standards to
be applicable to the site, they would not alter the remedial action selected.

INSTITUTIONAL CONTROLS:   Not applicable.
                                                B-73

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                       PERDIDO GROUNDWATER CONTAMINATION, AL
                                   First Remedial Action - Final
                                        September 30, 1988
ROD ABSTRACT
      The Perdido Groundwater  Contamination site is located in the Town of Perdido,  Baldwin County,
Alabama.  Site contamination occurred as a result of a 1965 train derailment on the Louisville and Nashville
Railroad (now CSX Transportation, Inc.).  Chemicals  (particulary benzene)  from derailed tank cars spilled
into  drainage ditches, infiltrating the underlying aquifer.  The area of ground  water contamination covers
approximately 15 acres and is centered downgradient about 300 yards from the derailment site.  The Alabama
Department of Public Health, Division of Public Water Supply (ADPWS) first documented reports of taste
and odor problems in resident's water wells in 1981. Further studies showed benzene contamination in 6 of
27 wells, which led to supplying bottled  water to 250  affected residents.  In February  1983 EPA provided
immediate removal funding to construct a water supply line  to connect to a nearby town.  CSXT voluntarily
provided funds for and installed the water system in July 1983.  The primary contaminant of concern affecting
the ground water is benzene.

      The selected remedial action  for this site includes:   ground water  pump and  treatment  using air
stripping or activated carbon adsorption with reinjection of treated water  back  into the aquifer, and air
monitoring during operations; and ground water monitoring to measure success of the cleanup. The estimated
capital cost for this remedial action is $169,000 with estimated  annual O&M cost  of $103,000.

PERFORMANCE STANDARDS OR GOALS:  The target cleanup goal for ground water is benzene 5 ug/1
(MCL).

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-74

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                         WAMCHEM, SC
                                   First Remedial Action - FINAL
                                           June 30, 1988
ROD ABSTRACT
      The 21-acre Wamchem site is located in Burton, Beaufort County, South Carolina, on a small island
in the midst of a salt marsh near  McCalleys Creek, a tidal stream.  The creek is considered to be a habitat
for the loggerhead turtle,  a federally listed threatened species, and a probable habitat for the short-nosed
sturgeon, also a federally listed  endangered species.  The water table aquifer at the site discharges into the
creek, and has no distinct confining unit separating it from the underlying Floridian aquifer, the principal
aquifer in the region.   Between 1959 and 1972,  the Beaufort Chemical and Research Company owned and
operated the site, producing dyes  for the textile industry. In 1972, M. Lowenstein Company purchased the
facility and continued operations  until  1981.   When  solvent  recovery  and recycling  operations  were
discontinued at the site, M. Lowenstein Company closed the plant in 1982.  Liquid wastes generated at the
site were discharged to a drainage ditch leading to two unlined ponds. A ditch was later extended from one
of the ponds, discharging wastes directly into McCalleys Creek.  Waste treatment methods  changed, and the
ponds and ditches were replaced by an unlined holding pond and a waste lagoon in 1972; however, these were
soon replaced by two  spray fields and a concrete-lined holding pond in 1975. In 1977, the South Carolina
Department of Health and Environmental Control (SCDHEC) required the company to use a spray-irrigation
technique to improve its  wastewater  process.   The wastes discharged onto the spray fields consisted of
neutralized  sulfuric acid and process water.  Although the  system was found  to be in compliance with
SCDHEC standards, ground water  contamination was documented at the site in 1982.   Current  soil and
ground water contaminants include:  VOCs, benzene, toluene, xylenes,  semi-volatiles, and organics.

      The selected remedial action for this site  includes:  ground water  pump and treatment using carbon
adsorption with offsite discharge to  a stream; excavation  and low temperature thermal aeration of 2,000 yd
of contaminated soil followed by onsite disposal; and ground water monitoring.  The estimated capital cost
for this remedial action is $1,310,000, with annual O&M of $155,100.

PERFORMANCE STANDARDS OR GOALS: Ground water cleanup goals were based on Federal Ambient
Water Quality Criteria.  Soil cleanup goals were based on estimates of contaminants that would not result
in future exceedances of AWQC in ground water at the source area due to soil contaminant leaching.  Some
individual goals include:   benzene 2.43 mg/kg, toluene 34.47 mg/kg,  total xylenes 67.58  mg/kg,  and
naphthalene 74.57 mg/kg.

INSTITUTIONAL  CONTROLS:  Not applicable.
                                                B-75

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                     Progress Toward Implementing Superlund:  Fiscal Year 1988
                                         ZELLWOOD, FL
                                    First Remedial Action - Final
                                         December 17, 1987
ROD ABSTRACT
      The 57-acre Zellwood site  is  located in  the  northwestern  corner of Orange  County,  Florida,
approximately one-half mile west of the unincorporated  town of Zellwood. Situated in a rural area, the site
is occupied by four industries and an open field containing a marshy wetland area. Approximately 300 homes
within a one-mile radius of the site depend on private wells  as their sole source of potable water.  Between
1963 and 1971, Drum Service Company of Florida,  a drum recycling facility,  operated a wastewater disposal
system without  a regulatory  permit,  treating and  disposing  of  generated wastewaters  in  two  onsite
evaporation/percolation ponds.  In 1980, the company eliminated the use of these ponds for waste disposal
and in August 1981 initiated drainage  and removal of  contaminated  sediments from  the  ponds.   Douglas
Fertilizer and Chemical Company and Southern Liquid Fertilizer discharged wastewater from, their production
process  into  three unlined surface  impoundments.   Additionally, from  1960  to 1983,  the Zellwin Farms
Company facility, a vegetable washing and packing plant, discharged wastewaters from the vegetable washing
process into a ditch.   From 1971 through 1985, the Drum Service Company  has had various types of waste
treatment  and disposal permits issued by the Florida Department of Environmental Regulation (FDER). To
date, the Douglass Fertilizer and Chemical Company and the Zellwin Farm Company have not been permitted
by FDER.  In  December 1982,  EPA representatives discovered an abandoned drum  storage  area in the
northern section of the Zellwood site.  Based on unsubstantiated reports from area residents, material in this
drum storage area may have been there for more than  20 years. In the fall of 1983, EPA oversaw a PRP
removal action  of the  abandoned drum area.  The primary contaminants of concern affecting the ground
water, soil, sediments, and sludge include:  organics, inorganics, metals, and  pesticides.

      The selected remedial action for this  site  includes:   excavation of soils and  sediments with  onsite
incineration and testing of residuals to determine appropriate disposal; ground water pump and treatment
with flushing of the treated ground water back through the abandoned drum area to  facilitate cleanup of
residual contamination; and a long-term ground water monitoring program for private  potable water wells.
The  estimated present worth cost for this remedial action ranges from $41,264,000 to $61,908,000.   O&M
costs were not provided.

PERFORMANCE STANDARDS  OR GOALS:  Not specified.

INSTITUTIONAL CONTROLS:   Not applicable.
                                                B-76

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  ALLIED/IRONTON COKE, OH
                                   Second Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The Allied/Ironton Coke site is located in the City of Ironton, Lawrence County, Ohio. This remedial
action addresses the Goldcamp Disposal Area (GDA)  operable unit of the site.  The other operable unit,
comprised of the coke plant, lagoons, and the tar plant, is addressed in a separate remedial action. The GDA
is a four-acre  disposal pit located in a mixed industrial/business/residential area bounded by Third Street
on the east and the Ohio River on the southwest.  Several businesses and institutions are within 100 feet of
GDA.  Allied  Chemical and Dye Company has owned  the property since 1955.  The GDA was  a  sand and
gravel pit used for disposal of various chemical wastes from three sources between 1945 and  1977.  The
wastes include: anthracene residue, anthracene salts, phthalic anhydride residue, and miscellaneous process
wastes from the Tar Plant; foundry sand  containing heavy metals, phenolics, and  oils from the Dayton
Malleable Iron Company; and wastes disposed of by the Goldcamp Gravel Company.  In 1977, Allied decided
to discontinue  use of the GDA for disposal of chemical wastes. Allied and its contractor, in consultation with
the Ohio Environmental Protection Agency (OEPA), completed a  closure project at the site in August 1980,
which involved removal of standing  liquids  and filling and  capping the site with clay.   Subsequent
hydrogeologic  and  water quality investigations indicated that there is ground water contamination at the site
which may  pose  a  threat to  public  health through  migration.   The volume  of the disposal area  is
approximately  300,000 yd .   In addition  to  this primary  area of  contamination,  there  is  a  zone  of
nonaqueous-phase  contaminants which have migrated through the aquifer  to  the underlying impermeable
bedrock layer.  The extent of the contaminated area is  uncertain, but the volume is estimated to be 156,000
yd .  The surface  of the GDA is also  a source of contamination because many substances have oozed up
through the existing cap.  The primary contaminants of concern affecting the soil and ground water are VOCs
including benzene,  other  organics including phenols and PAHs, and  inorganics  including cyanide.

      The selected remedial action for this site includes:  construction of a slurry wall around the disposal
area from ground  surface into the  low permeability bedrock; installation of a multi-media RCRA cap over
the surface of  the disposal area; extraction  and onsite  treatment of ground water from inside  and outside the
containment system; provision of an alternate water supply for the  Ironton Iron  Company until ground water
cleanup levels  are  met; imposition of deed  restrictions to limit future uses of the property; and preparation
of a supplemental  RI/FS to identify the extent and nature of the  nonaqueous-phase contaminant layer with
implementation of the Agency-approved  remedy for  this  contamination, if  different  from  the present
containment alternative. The estimated present worth cost for this  remedial action is $13,130,000 with annual
O&M costs  of $515,000 for approximately 30 years.

PERFORMANCE  STANDARDS OR GOALS:  The selected remedy will meet ground water cleanup goals
based on MCLs, AWQCs and 10"6 health-based levels.  Specific goals include:  ammonia 0.50 mg/1, chloride
250 mg/1, total cyanide 0.2 mg/1, phenolics 0.3 - 3.5 mg/1, benzene 0.005 mg/1,  naphthalene 0.69 mg/1, and
PAHs (benzo-a-pyrene indicator)  0.005 ug/1.  The ground water cleanup ARARs and TBCs  may not be
technically feasible to attain,  particularly  for  benzene  and  PAHs; therefore,  technical feasibility will be
evaluated  every five years throughout the  remedial action.  An ARAR waiver  may be appropriate  if it is
determined that these standards cannot be  met.

INSTITUTIONAL  CONTROLS: Deed restrictions will be imposed to limit future uses of the property.
                                                B-77

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    BELVIDERE LANDFILL, IL
                                    First Remedial Action - Final
                                            June 29,  1988
ROD ABSTRACT
      The Belvidere Landfill (BL), occupying 19.3 acres of the 139-acre site, is located just outside the City
of Belvidere, County of Boone, Illinois. The site is located within the 100-year flood plain of the Kishwaukee
River, which is adjacent to the site.  Located within the site boundaries are  two ponds and a drum disposal
area.  The City of Belvidere owned the landfill from 1939 to 1973, operating  first as a municipal landfill until
1965, and then as an industrial landfill until 1973.  In late 1970, the City of Belvidere applied for a solid waste
disposal permit.  The application was to permit the disposal of 52 tons per day of domestic garbage, landscape
wastes, partially dewatered sludge, and demolition material.  However, in 1971, the operator disclosed that
up to 100 tons per day of wastes were being deposited.  This waste consisted of 35 tons of residential waste,
30 tons of industrial source waste, and 35 tons of commercial source waste. Approximately 790,000 yd  of
waste were  disposed of  at the landfill. IEPA denied the City's permit application in January 1971, and the
landfill was formally closed in 1973.  Between 1975 and 1982, IEPA repeatedly cited the landfill for inadequate
cover violations.  In the  summer of 1979, sand from adjacent areas and prairie plant vegetation were applied
as a final cover.  The primary contaminants of concern affecting the soil and  ground water include: organics,
PCBs, PAHs,  metals,  and lead.

      The  selected remedial  action for this site  includes:   RCRA Subtitle C capping  over  the 19.3-acre
landfill; treatment or  containment of soil from  the drum disposal area following resampling to determine
the  magnitude of PCB  contamination; ground water pump and treatment, possibly using air stripping with
discharge to either the  Kishwaukee  River or the city treatment plant; ground water  monitoring; pond and
river fish monitoring; installation  of an upgraded fence; deed restrictions  to control unacceptable  onsite
activities and  construction; and flood control measures  to prevent erosion of the cap and landfill contents.
The estimated capital cost for this remedial action is $5,900,000 with annual O&M of $271,000.

PERFORMANCE STANDARDS OR GOALS:  The ground water extraction and treatment  system will operate
until a 10"6  cumulative life-time  cancer risk is met at the point of compliance. PCBs greater than 50 mg/kg
will be disposed  of or incinerated offsite.  PCBs less than 50 mg/kg will  be  consolidated  on the  landfill.
Quantitative goals were  not specified for other contaminants.

INSTITUTIONAL CONTROLS:   Access restrictions  involve upgrading  the  existing  fence  to  prevent
recreational use of the landfill and to ensure the integrity of the  cap.  Deed restrictions  include controlling
unacceptable onsite construction and activities.
                                                 B-78

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                      Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    COSHOCTON LANDFILL, OH
                                     First Remedial Action - Final
                                            June 17, 1988
ROD ABSTRACT
      The Coshocton City Landfill  (CCL), an 80-acre landfill, is located in Franklin Township, Coshocton
County, Ohio.  The landfill is built on abandoned, subsurface strip mines, where an extensive network of
mine shafts were developed.  CCL is located between two small intermittent creeks that drain toward the
Muskingum River, 1.5 miles to the west of the site.  The area is characterized by considerable topographic
relief, with  small  streams situated between steep rolling hills.   Most of the surrounding land  is either
woodlands or pasture land used for cattle grazing.  The landfill property was used in  the early 1900s, and
again from the mid-1950s until mid-1979,  for subsurface shaft mining of coal.  The city conducted landfill
operations at the site between 1968 and 1979; however, the operations were not well recorded.  The waste
received  at the landfill consisted of mixed municipal  refuse and  industrial wastes including relatively inert
solid scrap wastes, nonhazardous materials, and hazardous liquid waste types  such as spent chlorinated
solvents,  non-chlorinated flammable solvents, resins, and plasticizers.  Much of the landfilled waste is situated
in the void created by abandoned  strip mine operations. Some waste was also reportedly placed in shallow
excavations in the southern portions of the site.  Currently,  portions of the landfill site are covered with what
appears to be mine spoil materials.  The cover on the site, however, is not consistent, with little or  no cover
in some areas.  In addition, standing water is observed in several areas.  Scattered surface deposits of drums
and other metal objects are present at the site.  Numerous leachate seeps exist on portions of the landfill.
The  primary contaminants of concern affecting  the surface and  ground water at  this site include:  carbon
disulfide, TCE, PAHs, chlorinated and non-chlorinated solvents, and heavy metals (mostly arsenic).

      The selected remedial  action for this landfill includes:  installation of a 2-foot low permeability soil
cap over the landfill,  with top soil and vegetation; imposition of deed restrictions, including fencing; filling
and grading the necessary areas; and possible installation of a gas collection and venting system, as well as
a leachate collection system  and a  drainage layer.  This remedial action will also include routine ground and
surface  water  and  sediment  monitoring  to  identify changes  in  contamination  concentrations.    The
implementation of this remedial action will entail a capital investment of $8,010,000 with a present value of
O&M cost of $910,000  associated  with the remedy.

PERFORMANCE  STANDARDS  OR  GOALS:   The goal of this remedy  is to  reduce the contaminant
concentrations in the  soil, surface, and ground water.  The current health-based risk levels for these media
are:  3 x 10" , 3 x 10" , and 3 x 10"   (all  for arsenic), respectively.

INSTITUTIONAL CONTROLS:   Deed restrictions would support and strengthen  the effectiveness of the
soil cover in limiting direct contact.
                                                 B-79

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                           EAU CLAIRE MUNICIPAL WELL FIELD, WI
                                    First Remedial Action - Final
                                           March 31, 1988
ROD ABSTRACT
      The 500-acre Eau Claire Municipal Well Field (ECMWF) site is located in northwestern Eau Claire
County and southwestern Chippewa County, Wisconsin, at the confluence of the  Eau Claire River and the
Chippewa River.  ECMWF supplies  drinking  water  to approximately 57,600  residents and numerous
commercial  establishments in the city of Eau Claire and Washington Township.   Ground water from five
municipal wells in the north  well field is contaminated with VOCs.  The contamination at the ECMWF site
has been characterized as two separate plumes with the estimated volume of contamination at  Plume 1 and
2 of 1.9 x 108 ft3 and 2.6 x 108  ft3, respectively.  The Chippewa River is not believed to be affected by this
VOC contamination due to  municipal well pumping which prevents ground water discharge into the river.
In March 1981,  as part of the  EPA Ground Water Supply Survey, the Wisconsin Department of Natural
Resources (WDNR)  tested the  Eau Claire municipal water supply for VOCs and did not detect VOCs at
levels of immediate concern. Additional testing of the city's active production wells in January 1982 showed
VOC concentrations below health advisory levels.  Due to concern about the future use of the water supply,
additional testing was conducted in September 1982 and January 1983 to identify the source  and extent of
VOC contamination.  Several residential wells reported detectable levels of VOCs including 1,1-dichloroethene
concentrations in excess of the WDNR health advisory. The primary contaminants of concern affecting the
ground water are VOCs including: chloroform, DCE, dichloroethene, PCE, TCE, and trichloroethane.

      The selected remedial action  for  this  site includes:   ground water pump and treatment using the
existing air stripper with discharge of treated water to the municipal water system and untreated water to
the Chippewa River; and provision of municipal water to private well users within or near the area of ground
water contamination.  The estimated capital cost for this remedial action is $1,214,200 with annual O&M of
$396,700.

PERFORMANCE STANDARDS OR GOALS:   Individual contaminant goals are below  MCLs and State
Health Advisory levels,  are  based on the achievement of an  additive 10~  risk level.  The target cleanup
levels (TCLs) for Plume 1 include: trichloroethene 0.5 ug/1, 1,1-dichloroethene 0.1 ug/1, and tetrachloroethene
0.01 ug/1. The TCLs for Plume 2 include: trichloroethane 0.4 ug/1, chloroform 0.06 ug/1, 1,1-dichloroethene
0.007 ug/1, and tetrachloroethene 0.09 ug/1.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-80

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  FOREST WASTE DISPOSAL, MI
                                   Second Remedial Action - Final
                                           March 31,  1988
ROD ABSTRACT
      The Forest Waste Disposal site consists of an 11-acre,  abandoned  municipal and industrial waste
landfill and 9 surface impoundments.  It is located in Genesee County, Michigan, 20 miles northeast of Flint,
and is surrounded by agricultural  land and undeveloped woodlands  and wetlands.  An estimated 20 to 30
households are located within a quarter mile of the  site.  Wetlands in the site vicinity drain into Butternut
Creek which eventually discharges  into the Flint River.  The site  is underlain by two drinking water aquifers.
Forest Waste Disposal conducted landfill operations from 1972-1978, receiving limited types of liquid industrial
waste, general household refuse, and drummed waste until  1978.  Specific waste material found within the
landfill includes PBB-contaminated feed, septic sludge, and drums containing primarily solid and liquid VOCs
in high concentrations.  The operator was also suspected of discharging liquid  wastes into the landfill and  onto
the ground.  In 1982,  the  site was  placed  on the  NPL.   This  remedial action addresses the landfill and
contaminated ground water on  the  east end  of the site.  Contamination from the  nine waste lagoons is
considered to be the primary source affecting  ground water and is addressed in a previous remedial action,
which includes: offsite treatment and disposal of lagoon liquid, with  onsite treatment and offsite disposal of
lagoon sediment, sludge,  and  soil.  The primary contaminants of concern affecting the soil and ground water
are VOCs including toluene  and  TCE, other organics  including pesticides, PAHs, and PBBs, and metals
including arsenic and lead.

      The selected remedial action  for this site includes:  removal and either  onsite or offsite incineration
of approximately 4,000 drums and 1,000 yd  of associated contaminated soil;  installation  of a containment
system including a RCRA cap, slurry wall, dewatering system, and a leachate collection system; and treatment
and disposal of collected leachate.  The ground water remedy includes:   deed restrictions  to prevent  use of
the ground water as a drinking water source; access restrictions; and ground water monitoring. The estimated
present  worth cost for  this  remedial action is $23,820,000 with an annual O&M of $440,500.

PERFORMANCE STANDARDS OR GOALS:  The remediation  of the landfill will  prevent  migration  of
contaminants to a drinking water aquifer in excess of MCLs, lifetime health  advisories, and noncarcinogenic
reference  doses, and will result in  an excess lifetime cancer risk range of 10"  to 10" .  The remedial action
will also prevent  migration to  surface water bodies in  excess of  Federal and State water quality criteria.
Cleanup goals for individual chemicals were not specified.

INSTITUTIONAL CONTROLS:  Deed restrictions will be implemented to prevent use of the ground water
onsite and from areas adjacent to  the site as a drinking water source.
                                                B-81

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  FORT WAYNE REDUCTION, IN
                                    First Remedial Action - Final
                                           August 26, 1987
ROD ABSTRACT
      The 35-acre Fort Wayne Reduction site  (FWD) is a former municipal landfill/waste disposal facility
located  along the Maumee River just east  of the city of Fort Wayne, Allen County, Indiana.  Two onsite
areas are designated as wetlands.  In addition, the site lies within a 100-year flood plain.  The primary land
use in the general area is light industrial and commercial. In addition, other landfills, a wastewater treatment
plant and sludge drying beds are located along the Maumee River in the vicinity of the site. Two residential
communities are located  approximately one-half mile  from  the site.  Before 1967, the site was uncultivated
farmland often  used  for the dumping of unknown waste.  The site accepted residential and industrial wastes
from 1967 to 1976.   Few records were kept on the  volume and composition of wastes, or on the industries
that generated  the wastes.  From May  1967 to August  1970, FWD was issued a county permit for public
disposal of garbage and rubbish.  Wastes were incinerated and the residual ash disposed of onsite.  In 1970,
FW changed its name to  National Recycling  Corporation (NRC) and built a recycling plant which apparently
became inactive after February 1975.  Inspection reports indicated that  deposited refuse included:  industrial
and liquid wastes, municipal wastes, garbage, paper,  and wood.  A 40- to 60-foot diameter pit adjacent to the
Maumee River contained pools of volatile liquids.   Wastes were disposed of into the pit by cutting off the
drum tops and emptying the  contents into  the pit.  NRC operation became part of Service  Corporation
America (SCA) in 1973.  In 1974, SCA was denied a municipal refuse permit due to site closure problems
encountered following high water levels.  Hazard  Ranking System  records indicate the  entire site's waste
quantity was equivalent to 2,820 fifty-gallon barrels.  In 1984, Waste Management  Inc. (WMI) acquired SCA
and conducted  an initial  site  investigation.  The site has been inactive  since 1976. The site  consists of two
characteristically different areas reflecting its historical  use:  the eastern half of the site was used as the
municipal/general refuse landfill (approximately 15 acres), and the western half of the site (approximately five
acres) was used for disposal of industrial wastes, building debris, barrels of unidentified wastes,  and residual
ash from earlier incineration operations.  Presently, soil and ground water are contaminated with 43 chemicals
of concern including:  metals, organics, PCBs, PAHs,  phenols, and VOCs.

      The selected remedial  action for the eastern portion of the site includes: deed and access restrictions;
soil capping consistent with State solid waste closure requirements; and long-term ground water monitoring.
The selected remedial action for the western portion includes:  excavation, re-consolidation, and on-  or offsite
incineration of approximately 4,600 drums  containing liquids from  Area C, followed by soil capping in
accordance with "hybrid" (alternate landfill)  closure  requirements; ground water collection and treatment, if
necessary, with discharge to the river;  deed and  access restrictions;  provision  and maintenance of flood
protection measures  for the portions of the site within  the 100-year floodplain; and compensation for any loss
of wetlands due to remedy  construction by enhancing  onsite wetlands.   The estimated present worth cost for
this remedial action  is $10,020,000.

PERFORMANCE STANDARDS OR GOALS:  Contaminant levels in the area of the municipal landfill do
not pose a threat to human health or the environment.  Ground water monitoring will ensure protection of
the river through the  use  of ACLs as a performance standard.  Specific  goals will be determined during
design.  MCLs  are not considered ARARs, since ground water is not used  as a drinking water source.   The
fate of ground  water in the waste disposal facility area will be determined  during design.

INSTITUTIONAL CONTROLS:  Deed restrictions  will  be implemented to control future development and
ground  water use at the  site.
                                                 B-82

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     IMC/TERRE HAUTE, IN
                                   Second Remedial Action - Final
                                            June 22, 1988
ROD ABSTRACT
      The IMC/Terre Haute site is located in southeastern Terre Haute, Vigo County, Indiana. The 37-acre
site is bordered on the west by the Milwaukee, St. Paul, and Pacific Railroad and on the east by the Louisville
Railroad.  The site is part of a semi-industrialized area of Terre Haute and is 1.8 miles east of the Wabash
River and 1 mile north of the Thompson ditch. A waste disposal area, encompassing approximately six acres,
is located in  the northeastern portion of the plant site.  From 1946 to 1954 a small facility on a  six-acre
segment  of the  property  manufactured,  packaged, and warehoused technical-grade benzene hexachloride
(BHC-tech).  This material was confined to areas sold to insecticide manufacturers as a raw material for the
production of insecticides, including lindane. The site has been owned by International Minerals and Chemical
Corporation since 1975.   IMC conducted  surficial  and  subsurficial soil  sampling in  1979,  finding that
contamination was confined to areas within seven feet of the surface and well above the ground water table.
Seven ground water monitoring wells were installed  at the site, and samples  indicated measurable BHC
concentrations in two of the wells.  In 1980, approximately 28,500  yd of soil, rubble, piping, and other debris
were excavated and placed in a secure clay-capped mound to prevent offsite migration of BHC-tech. The
cap system included a surface drainage collection system and soil gas venting.  The concentration in ground
water of lindane, the gamma isomer of BHC, declined relatively quickly after construction of the mound and
has continued to decline at a slower rate since 1983.   The soil cleanup and mound construction has proven
to be effective in containing the source of BHC-tech and  in reducing ground water contamination to MCL
and MCLG concentrations.  The primary contaminants of concern are lindane and total BHC.

      The selected remedial action for this site is no further action with a maintenance  program, which
includes:  inspection of the existing cap quarterly and maintenance of the  vegetative  cover; initiation of a
ground water monitoring  program (sampling of upgradient and downgradient  wells semi-annually for the
next five  years and then annually until 2010); access  restrications; and establishment of a contingency plan.
The estimated present  worth cost for this remedial action  is $159,000 for O&M of the existing system.

PERFORMANCE STANDARDS OR GOALS:  Contaminant levels immediately  downgradient of the mound
are well   below the MCL (4.0  ug/1)  and  MCLG  (0.2 ug/1)  for  lindane in  drinking  water.   Should
contamination reach the MCLG  level or show a  consistent, significant (order of magnitude) rise above
prevailing levels over more than two monitoring periods,  additional samples will be taken to determine if
remedial  action may be necessary.

INSTITUTIONAL CONTROLS: Deed restrictions will be imposed on land  use of the property.
                                                B-83

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                               KUMMER SANITARY LANDFILL, MN
                                       Second Remedial Action
                                         September 30,  1988
ROD ABSTRACT
      The Kummer Sanitary Landfill is  a 40-acre  site located  in Northern Township, Beltrami County,
Minnesota. The site consists of a 35-acre landfill and the Kummer residence located in the extreme southeast
corner of the property.  To the north and west of the site, the land is sparsely settled with  farm residences.
A large residential community lies about 1,000 feet to the east and west, and the City of Bemidge is located
one-half mile south of the site.  The city uses ground water  for its drinking water; its wells are one-quarter
mile west of the site.  There are numerous wetlands and lakes within the area of the site.  Between 1971 and
1983 the site operated as a sanitary landfill, accepting mixed municipal waste.  Landfill operations consisted
of excavating trenches, filling the trenches with waste materials, and covering the fill with  onsite sand and
gravel deposits.  The  trenches may have been excavated to  the water  table and the waste  placed in direct
contact  with  ground water.   Beginning in 1974,  demolition debris  consisting  of  fly ash  and sawdust were
disposed of onsite.  In 1982 and 1983 the Minnesota Pollution Control Agency sampled ground water from
onsite monitoring wells  and discovered 19 VOCS including TCE,  PCE, and  benzene. In L984, VOCs were
also discovered in offsite shallow residential wells downgradient of the site; consequently, in 1985 the site was
ordered closed.  In June 1985 a ROD was signed to provide an alternate water supply to approximately 244
homes affected by contaminated ground water.  The primary contaminants of concern affecting ground water
and soil are VOCs such as TCE, PCE, and benzene.

      The selected remedial action  for this site includes:  site grading and consolidation of soil and other
waste material;  placement  of a sloping foundation layer of natural soil  fill;  capping with  a cover system
consisting of a  gas control layer, a barrier  layer of low permeability material  (clay or flexible synthetic
membrane),  and a drainage layer with placement  of cover soil and  a  vegetative layer; access and deed
restrictions limiting future site use; and groundwater and landfill gas monitoring.   The estimated capital cost
of the selected remedy  is $7,400,000 to $12,500,000  for the  clay  cap and $6,900,000 to  $11,200,000 for  the
synthetic membrane, with annual O&M costs of $35,000 and $33,000, respectively.

PERFORMANCE  STANDARDS OR GOALS:  Not applicable.

INSTITUTIONAL CONTROLS:  Access  and deed restrictions will be implemented  to limit future use of
the property.
                                                B-84

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                              LASALLE ELECTRICAL UTILITIES, IL
                                   Second Remedial Action - Final
                                          March 30,  1988
ROD ABSTRACT
      The LaSalle Electrical Utilities  (LEU) site is  located in the city of LaSalle, west-central LaSalle
County, in north-central  Illinois.   There are approximately 190 people and 70  residences located  within
one-eighth mile of the LEU property. LEU, a former manufacturer of electrical equipment, began operating
prior to World War II. Between the late 1940s and 1978, PCBs were utilized in the production of capacitors.
Undocumented reports allege the application of PCB-contaminated waste oils as a dust suppressant both on
and off the property until as late as 1969.  Following the regulation of PCBs, manifests document the disposal
of PCBs at all regulated facilities.  Beginning in September 1975, numerous government agencies conducted
various inspections and issued complaints and orders to the LEU company as a result of its manufacturing
and handling practices. Soil  sampling conducted by the Illinois Environmental Protection Agency (IEPA) in
December 1980  documented onsite  PCB  contamination.    Continued  soil sampling   revealed  offsite
contamination in March and May 1981.  The IEPA ordered the company to cease operations in May 1981.
The U.S.  EPA conducted Immediate Removal Actions that involved fencing the LEU property and capping
a portion  of the heavily contaminated onsite property; capping contaminated offsite property to the south of
the site; and staging, sampling, and packaging PCB waste material for future disposal.  The first operable unit
ROD, signed September 19, 1986, addressed offsite soil contamination. This second remedial action operable
unit addresses PCB and VOC contamination-in soil, sediments, building structures, and ground water.

      The selected remedial action for this site includes:  excavation and onsite incineration of contaminated
soil and replacement with clean fill; high pressure flushing and mechanical cleaning of affected sewer lines;
excavation and  onsite incineration of contaminated sediment from  the unnamed  creek  downstream  of the
storm sewer discharge; ground water collection and onsite treatment using phase  separation, filtration, and
air stripping with discharge to the local  waste water treatment plant via sanitary sewers; and demolition and
offsite disposal of contaminated LEU building structures.  The estimated present worth cost for this remedial
action is $34,495,180.

PERFORMANCE STANDARDS OR GOALS:  Contaminated ground water will be collected to achieve  MCLs
for VOCs (specific chemicals and associated values not specified) and PCBs 1 ug/1.  Soils will be excavated
consistent  with the cleanup levels selected in the  1986  ROD.  Specifically, the levels for  PCBs  are 5 mg/kg
in surface  soils and 10 mg/kg at depths greater than one foot when clean fill material is used to return the
area  to its original grade.

INSTITUTIONAL  CONTROLS:  Not applicable.
                                               B-85

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                       LONG PRAIRIE, MN
                                    First Remedial Action - Final
                                           June 27, 1988
ROD ABSTRACT
      The Long Prairie site, as defined by the extent of the plume of contaminated ground water, extends
2,100 feet by 1,000 feet in Long Prairie, Todd County, Minnesota. The Long Prairie River flows within 500
feet of the contaminant plume.  In August and October 1983,  routine  municipal well monitoring by the
Minnesota Department of Health (MDH) indicated contamination in two of five municipal wells. The MDH
ordered the two wells  shut down in October 1983, and in November 1983 issued an advisory to provide
bottled water for area residents. About 50 of the area's 300 private wells were affected by the ground water
contamination. Since the advisory was issued, 39 of the 45 homes using contaminated ground water have been
connected to the municipal drinking  water system.  Well monitoring in 1984 implicated an area dry cleaning
operation as the potential source of contamination. The primary contaminants of concern affecting 7,000,000
gallons of ground water and 3,800 yd3 of soil are VOCs including DCE,  PCE, and TCE.

      The selected remedial  action for this site includes:  ground water  pump and treatment using  air
stripping with discharge to the  river; spill treatment using active soil venting; and ground water monitoring.
The estimated capital cost for this remedial action is $890,000 with annual O&M of $390,000 for year 1 and
$250,000  for years 2-5.   The estimated present worth cost for this  remedial action is $2,000,000.

PERFORMANCE STANDARDS OR GOALS:  Remediation will attain a 10"6 increased  cancer risk  level.
Based on this level, PCE will be treated to 1,200 mg/kg and 5 ug/1 in soil and ground water, respectively.
The target ground water cleanup level for TCE is expected to be below the MCL value of 5 ug/1.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-86

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                 MASON COUNTY LANDFILL, MI
                                        First Remedial Action
                                         September 28, 1988
ROD ABSTRACT
      The Mason County Landfill site is located three miles south of the City of Ludington, Mason County,
Michigan.  The site  occupies approximately 18 acres of a predominantly rural area in Pere Marquette
Township.  Approximately 10 acres of the site were used as a  landfill.  Less than 500 feet from the landfill
there is  a wetland area which drains into Babbin Pond, the headwaters of Iris Creek. There are 14 residential
wells within a one-half mile radius of the landfill.  The  population within a three mile radius of the site is
estimated to be 1,112.  The Mason County Department of Public Works (DPW) leased the property in 1971
and entered into an agreement with Acme Disposal, Inc., to operate the site as a sanitary  landfill. Although
the Michigan Department of Natural Resources (MDNR) documented that slurry and sludge wastes from local
industries were being dumped at the  landfill, the site's license was  renewed annually until it was closed in
August  1978 after reaching capacity. Public concerns over the water quality in Iris Creek prompted the DPW
and  MDNR  to  review  closure activities.   The  site  is  currently  owned  by  Mason County  as  result  of a
settlement with two property owners who filed suit against the county.  In 1983, a clay cap was installed over
the landfill, and berms and  storm drains were constructed to improve  site drainage.   Two surface  aerators
were installed in Babbin Pond to  facilitate biodegradation of organic matter and 15 gas vents were placed in
the top  of the landfill.  The site has been separated into  two operable units; one for the landfill contents and
one for  the ground water.  This source control remedial action addresses the landfill contents. Contamination
of the shallow and deep aquifer will be addressed in a subsequent remedial action. Site investigations indicate
that  contamination of surface water, surface sediment, soil, and  offsite air quality are not sufficient to warrant
remedial  action.  The primary contaminants of  concern affecting  the ground water are VOCs including
benzene, PCE, TCE,  and xylene.

      The selected remedial action for this site  includes:  construction of a RCRA  cap over the landfill;
access restrictions; deed restrictions on and near the  site to prohibit use of the shallow aquifer; and ground
water monitoring.  The estimated  present worth cost for this remedial action is $2,800,000, with present worth
O&M costs of $1,000,000 over 30 years.

PERFORMANCE STANDARDS OR GOALS: The general remedial action goals are to prevent direct contact
with  contaminant sources  and to minimize future release of contaminants.  Establishment of performance
standards for the cleanup of ground water contamination is deferred until a remedy is selected for the ground
water operable unit.

INSTITUTIONAL CONTROLS:   Deed restrictions will prohibit future site  development or installation of
water supply wells on the  site.
                                                B-87

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                              MID-STATE DISPOSAL LANDFILL, WI
                                    First Remedial Action - Final
                                         September 30, 1988
ROD ABSTRACT
      The Mid-State Disposal (MSD) site is  an abandoned municipal  and industrial wasle landfill located
in central Wisconsin, in Cleveland Township, Marathon County, about four miles northeast of Stratford.  The
area surrounding the site includes an abandoned railroad track partially bounding the west and north, two
offsite sludge disposal lagoons owned by Weyerhaeuser, Inc., to the northeast,  and  private property to the
south.  Site runoff enters nearby waterways including the Rock Creek and the Eau Plune River via unnamed
tributaries. Additionally, ground water from the site is believed to be discharging into a ravine 500 feet south
of the site.   MSD  conducted landfilling operations from  1970-1979,  receiving municipal, industrial,  and
commercial wastes as well as construction and demolition debris. Specific wastes received included papermill
sludges, asbestos dust, solvents, pesticides, paint sludges, and metals.  Four areas of contamination have been
identified at the site. These are:  a 25-acre landfill  located in the center of the site and referred to as the
Old Mound area, which contains municipal wastes, papermill sludges, asbestos dust, pesticides, and solvents;
a five-acre interim expansion  landfill located  to  the west of the Old  Mound  area  and referred to  as the
Interim  Expansion area, which reportedly contains wastes similar to the Old Mound  area with the exception
of papermill sludges; a three-acre sludge lagoon  located northwest  of the Old  Mound area which  allegedly
contains papermill sludges; and an area along the western edge of the property where leachate ponding had
occurred.  Numerous environmental problems and permit violations were noted by the Wisconsin Department
of Natural Resources (WDNR) during a site  inspection  in 1974.  In 1979,  Weyerhaeuser  Company, a
generator  of waste disposed at the facility,  agreed to abandon the facility properly.   The pond leachate was
removed, and the three waste disposal areas were covered.  Leachate collection systems were installed in late
1979 for both the sludge lagoon and the Interim Expansion  area; only the leachate collected from the latter
is currently  removed and treated offsite.  Subsequent  investigations revealed  that ground water has been
contaminated by leachate percolating from the waste  disposal areas and the leachate  pond down  to the
underlying aquifer.  The primary contaminants of concern affecting the ground water, surface water, and soil
are VOCs including benzene, PCE, TCE, and metals.

      The selected  remedial action for this site  includes:  installation of new soil/clay caps for the  lagoon
and landfills; site monitoring that includes ground water surface water, and landfill gas monitoring; offsite
ground  water  monitoring; provision of an alternate water  supply  for  nearby residences; improvement  of
surface  water  drainage;  leachate  and ponded water  collection and offsite treatment;  access  restrictions;
institutional controls  to prevent well installation  onsite; and in situ solidification/stabilization of sludge  as
necessary  for cap  support, and  landfill  gas flaring, if deemed necessary during pre-design.  The estimated
present  worth for this remedial action  is $16,000,000 with annual O&M of $22,000 for the first year, and
$100,000 for years 2-30.

PERFORMANCE STANDARDS OR GOALS:  Ground water will  gradually meet state  standards  and  10~6
cancer risk levels for ingestion as a result of natural attenuation and a  decrease in leachate contamination.

INSTITUTIONAL CONTROLS:  Institutional controls will be established to prevent onsite well installation
and soil excavation.
                                                 B-8

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                           NL/TARACORP/GOLDEN AUTO PARTS, MN
                                   Second Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The NL/Taracorp/Golden Auto Parts site is located in St. Louis Park, Hennepin County, Minnesota.
A secondary lead smelting facility operated onsite from 1940 until 1982.  Land use adjacent to the site is light
industry.  There are residential  areas within  one-quarter mile of the site  to the north,  east, and west.
Aquifers beneath the site serve as primary sources of drinking water in the area, supplying 90 percent of all
ground water used in the region.  The site was originally owned by NL Industries, Inc., but was later divided
and each portion sold to a succession of owners.  One of these owners, Taracorp,  owned and operated the
lead smelting facility from August 1979 until February 1981.  Secondary lead smelting operations recovered
lead from lead plates,  battery fragments, and  lead  containers.  The  industrial operations and onsite waste
disposal  activities  resulted in elevated lead levels  in air and  onsite soil.   Under a  Consent Order, NL
conducted onsite investigations and  cleanup activities between 1985 and 1988 including soil remediation,
capping the site with asphalt,  and establishing a long-term ground water monitoring  program. As part of the
Consent  Order,  NL  was also required to investigate and, if necessary, clean up soil near the site possibly
contaminated by windblown  contaminants.  This  remedial  action addresses the possibility of offsite soil
contamination.  Investigations indicate that offsite soil does not contain elevated levels of lead attributable to
the site.  There  are no contaminants of concern attributable to the site affecting the offsite soil.

      The selected remedial  action for this site is a no action remedy. The one residential yard that exceeds
state and ATSDR guidance levels for soil lead is not clearly attributable  to the site, but will be addressed
through a cooperative  cleanup by NL Industries.   There is no capital cost  or O&M associated with this
remedial action.

PERFORMANCE STANDARDS OR GOALS:  The no action remedy attains the state ARAR of 1,000 mg/kg
for  soil lead,  as  well as the ATSDR guidance  level  of 500 to 1,000 mg/kg.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-89

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    NINTH AVENUE DUMP, IN
                                        First Remedial Action
                                         September 20,  1988
ROD ABSTRACT
      The Ninth Avenue Dump (NAD) is  a  17-acre inactive chemical and industrial waste  disposal site
located in Gary, Indiana.  NAD is located in a low-lying area with poor drainage.  Prior to filling, the site
consisted of parallel ridges separated by wetlands areas. Hazardous waste disposal activities occurred at the
site from  early  to mid 1970s with some  filling  continuing until  1980.  The  site  accepted dry industrial,
construction, and demolition waste; oil, solvents, paint solvents, and  sludges; resins;  acids; and flammable,
caustic,  and arsenic-contaminated materials.   A  small-scale auto  wrecking operation was observed  at the
property in 1975 by the Indiana State Board of Health (ISBH) which also documented  the presence of 10,000
55-gallon drums at the site, many of which were empty. Additionally, the ISBH estimated that approximately
500,000  gallons  of liquid  industrial waste  and 1,000 buried drums were present at  the  site.   Subsequent
inspection revealed portions of discarded auto batteries, drummed liquid wastes, and abandoned tanker trucks.
In 1975 and 1980 EPA ordered the site operator to initiate surface cleanups.  Subsequently, he removed some
barrels, junk cars, and trucks. This first operable unit addresses remediation of an oil layer  floating on the
ground water surface, the principal environmental threat at the site.  The quantity of oil under the site is
estimated  at 250,000 to 700,000 gallons, of which  100,000 to 500,000 gallons are estimated  to be recoverable.
Several organic  and  inorganic contaminants have been detected in the  oil  in  higher concentrations than  in
other media.  Oil seeps have been observed in onsite ponds leading to concerns that the oil may be affecting
aquatic life, and an oil sheen has been seen on several surface water bodies. The second operable unit will
address buried waste, contaminated soils, and contaminated ground water.  The primary contaminants in the
oil layer include: VOCs, benzene, toluene, xylene, PAHs,  organics, PCBs,  metals, and cyanides.

      The selected  remedial action for this site includes: construction of a soil-bentonite slurry wall  to
completely surround the hydrocarbon layer; separate extraction of oil and ground water through  a series  of
central extraction wells, followed by storage of the recovered oil in an  onsite storage tank and recharge  of
the treated ground water through recharge wells;  and ground water  monitoring.   Oil  treatment will be
evaluated  in the second operable unit along with treatment of the source material at the site.  The estimated
capital cost for this remedial action is $1,960,000 with annual O&M  of  $190,000.

PERFORMANCE STANDARDS  OR  GOALS:  The remedial action invokes the interim remedy waiver for
contaminant-specific ARARs in  ground water and  surface waters; however, ground water  extraction and
discharge  will meet MCLs.  Individual MCL goals were not specified.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                 B-90

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   OAK GROVE LANDFILL, MN
                                        First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The Oak Grove Sanitary Landfill  covers 45  to  50 acres  in Oak Grove Township,  Anoka County,
Minnesota, approximately 38 miles northwest of St. Paul.  There are 249 people that live within one mile of
the site and 6,786 reside within four miles.  The  majority of these residents depend  on water from wells
drawn primarily from the lower aquifer, or surface water  sources. Surface runoff from the  landfill empties
into a wetland to the south.  A creek flows through this wetland, discharging to Rum River two to three miles
southwest of the site. The landfill  received 200,000 to 300,000 cubic yards of  waste per year  from 1976 until
it reached its permitted capacity in late 1983.  Most of this waste consists  of household trash and garbage.
In addition, waste consisting of oil sludge from an oil recycling process, paint and solvent  wastes, foundry
wastes, metal  sludges, organic compounds from pesticide manufacturing,  cutting oils  and  lubricants, and
cleaning solvents and inks, are  reported to have been buried near the center of the landfill, but their exact
location is  unknown.  Minnesota Pollution Control Agency (MPCA) and Anoka  County records indicate a
number of violations and operational problems throughout the active history  of the site.  MPCA discovered
a ground water contamination  problem from monitoring  well  samples  obtained  at the site in 1984.  The
primary contaminants of concern affecting ground water and surface water are  VOCs including ethyl benzene,
toluene, and xylenes.

      The selected  remedial action for this  site includes:  installation  of  a  security fence;  capping with a
final cover system consisting of a gas control layer, a barrier layer of low  permeable material or a flexible
membrane and a drainage layer; topsoil cover  and vegetation; deed restrictions; consideration of treatment
options for air  emissions from gas  vents after construction of the  final cover;  consideration during design of
the need for extra protection for frost damage without  significantly increasing cost or  likelihood of failure;
and  air  and ground water monitoring.   The second remedial action  will address the  ground  water
contamination and possible  remediation of the  downgradient plume. The estimated present worth cost for
this remedial action  is $6,300,000 to $11,100,000 if a clay  barrier is installed, or $5,500,000  to $9,300,000 if
a synthetic membrane barrier is installed,  with  annual O&M  of $42,000  or  $40,000.

PERFORMANCE STANDARDS OR GOALS: This remedy addresses  control of contaminant migration and
risks associated with exposure to the contaminated materials, and therefore  no chemical-specific standards
apply.

INSTITUTIONAL CONTROLS: Deed restrictions will be implemented to  limit further use of the site.
                                                B-91

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                 PETERSEN SAND & GRAVEL, IL
                                    First Remedial Action - Final
                                         September 14, 1988
ROD ABSTRACT
      Petersen Sand and Gravel (PSG) is a 20-acre mining site and a former  disposal area located north
of Libertyville, Illinois.  The site is part of a  tract of land owned since 1979 by the Lake  County Forest
Preserve District  (LCFPD).  PSG is bordered by the Des Plaines River to the west, forest  preserve land
and residences to the east, and agricultural land and small business to the north and south.  The site consists
of three disposal areas including a three- to four-acre landfilled area reportedly containing construction debris,
trees, and tires; an area that contained 400 to 500 55-gallon drums of paint  and  solvent wastes; and an area
that  contained approximately 500 drums of solvents and 1,000 paint cans.  The  entire site is  approximately
20 feet below the elevation of the Des Plaines River due to mining operations which are still continuing and
are expected to continue until the early 1990s.  LCFPD is planning to construct a recreational lake at the site
when mining operations cease.  Raymond Petersen purchased the property in 1952, which included a 30-acre
parcel east and a 20-acre parcel west of the river and began the sand and gravel operations at the site later
that  year.  Between  1955 and  1958, unknown refuse was disposed of in the  four-acre landfill.  In 1971 the
Illinois Environmental  Protection Agency (IEPA) investigated reports of illegal dumping and subsequently
ordered immediate closure  of the site.  In 1973, the Illinois Pollution Control Board ordered complete waste
removal and covering of the refuse. Additional reports cited that numerous drums were not removed. These
wastes,  consisting of 55-gallon  drums of paint and solvent waste,  were removed in 1977.  An inspection
conducted in 1980 detected no additional buried drums.  The Lake County Grading Company (LCGC) took
over the mining operations in 1983, and discovered additional buried drums of solvents and paint cans. These
containers were removed from the area that year, along with contaminated soil.  In 1984, the site was placed
on the National Priorities List.  A 20-acre area in the northwest  corner of the site was the focus of concern.
The  final remedial  investigation  report conducted  by  IEPA  was completed in April 1988,  indicating  no
presence of contaminants at levels of concern,  thus  a feasibility  study was not necessary.  The investigation
analyzed over 150 organic and inorganic compounds, and only maganese and  iron exceeded secondary MCLs.

      The selected remedial action for this site  is no further action, since the findings in the RI indicated
that  previous removal actions were adequate and  that no unacceptable risk remained on site.  A lake will be
constructed onsite; therefore, surface water and sediment monitoring is recommended both before and after
the lake is in place.  Ground water  and precipitation collected in the mining pits will continue  to  be
discharged to the Des Plaines River in compliance with the  NPDES permit until the mining  operations cease.
There are no capital or O&M costs associated with this remedial action.

PERFORMANCE STANDARDS  OR  GOALS:   There are no  performance standards applicable for  this
remedial action since a remedy of no  further action was selected.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-92

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                         POER FARM, IN
                                    First Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The 4.5-acre Poer Farm site is located about four miles north of Charlottesville, in Hancock County,
Indiana.  The site is an abandoned tract of land with a collapsed house and barn, and an old, inactive well
that lies southeast of the house.  The surrounding area is open farmland.  The nearest house is about one-
quarter mile from the site, and the nearby residents rely on private wells for their water supply.  There are
about 270 homes with a population of about 2,400 within three miles of the site.  In 1973, approximately 260
drums of offgrade  solvents and paint resins were stockpiled on the Poer property.  In 1981  and 1983, the
drums and an onsite well were tested and found to  contain elevated levels of arsenic, cadmium, lead,  and
mercury.  Emergency cleanup activities were conducted in the summer of 1983.  All wastes were removed
from  the site, and six to eight inches of soil  were removed from the drum storage areas.  Subsequent
sampling showed significantly decreased levels of the heavy metals.  The site was fenced and warning signs
were posted. An investigation in 1988 indicated  that contaminant levels were below Federal and State Health
Standards and that there was no threat to human health or the environment.

      The selected remedial action  for  this site is no  further action  once monitoring wells  have been
successfully  abandoned.   Previous  removal actions  were  adequate  to protect human  health, and  the
environment. There  are no costs associated with this no action remedy.

PERFORMANCE STANDARDS OR GOALS:  Not applicable.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-93

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                           PRISTINE, OH
                                     First Remedial Action - Final
                                          December 31, 1987
ROD ABSTRACT
      The Pristine, Inc., site is located in southwestern Ohio in the City of Reading (population 12,843), a
suburb of Cincinnati.  The site is bordered by residential and industrial areas.  Three hundred feet northeast
of the site is a residential trailer park.  Eight municipal water supply wells serving the citizens of Reading
are located approximately 300 feet northwest of the site. In 1974, Pristine, Inc., began liquid waste disposal
operations at the site.  Prior to 1974, the site was used for  the manufacturing of sulfuric acid. In the spring
of 1977, Pristine, Inc., obtained a permit to operate a liquid waste incinerator.  In April 1979, as  many as
8,000 to  10,000  drums and  several hundred thousand gallons of bulk liquids consisting of  acids,  solvents,
pesticides, PCBs, and other chemicals were found onsite. Disposal operations were ordered to shut down in
September 1981, in accordance with a  partial  consent order  with the State  of  Ohio. From June 1980 to
November 1983, much of the onsite waste was  removed  in accordance with a Consent  Decree  between
Pristine, Inc., and the Ohio EPA. Wastes stored  and subsequently removed from the site during this  period
included  paint sludges, lab packs, flammable solvents, cyanide wastes, pesticides, chlorinated  solvent sludge,
DDT,  "neutralized"  acid  sludge, PCB-contaminated soils, incinerator  ash, and  solvent/sludge  mixtures.
Between  March 1984 and July 1984, soil and waste  removal activities addressing immediate hazardous site
conditions  were performed  by some of the PRPs.   These  activities  did' not  address the long-term risks
associated with the site.  The results  of the RI/FS indicated  that over 90 compounds were detected in the
soil, ground water, surface water, and sediments including:  PCE, TCE, benzene, organics, metals, pesticides,
and dioxin (in soils and sediments only).

      The selected remedial action for  this  site includes: excavation and onsite consolidation on the surface
of the site of 1,725 yd of contaminated soils and sediments  from the  pit area; in-situ vitrification of 37,700
yd   (average of 10 feet  across the entire  2.2-acre site) of contaminated soils  and sediments  followed by
placement of a vegetative soil cover over the vitrified mass; ground water extraction and treatment using air
stripping with carbon off-gas and offsite discharge to a creek; decontamination, demolition, and offsite disposal
of all onsite structures in a solid waste landfill; installation of a french drain; and implementation of deed and
access restrictions. The estimated present worth cost  for this remedial action is $17,094,000 with annual O&M
of $94,800.

PERFORMANCE STANDARDS OR GOALS: The overall  health-based cleanup standard of 10"6 cumulative
excess cancer risk at the plume boundary will be met for all media. Chemical-specific ARARs were specified
for 30  contaminants based on RCRA  and  Safe  Drinking  Water  Act MCLs  and Clean Water Act  Water
Quality Criteria.

INSTITUTIONAL CONTROLS:  Fencing of the western boundary will limit site access and prevent exposure
to contaminants present  at  the site.  The  use of deed restrictions will  be considered during the  remedial
design.
                                                 B-94

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                 REPUBLIC STEEL QUARRY, OH
                                    First Remedial Action - Final
                                         September 30, 1988
ROD ABSTRACT
      The Republic Steel Quarry site is located in the City of Elyria in Lorain County, Ohio, southwest of
Cleveland.  The site is situated between West River Road and the West Branch of the Black River, directly
west across the river from Franklin  School.   The  site consists of a four-acre quarry containing water
surrounded by seven acres of fenced-in property. Elyria surrounds the site, with a population of approximately
58,000.  Prior to 1950, the site operated as a sandstone quarry.   From 1950 to 1972, approximately 200,000
gallons of waste pickle liquor (acid wastes used in steel processing) were discharged to a ditch located on the
east side of the steel plant, which flowed north into the  quarry.  From  1972 to 1975 the  ditch was used for
disposing of rinse water from pickling operations. The ditch was dammed in 1976,  and after this time sulfuric
acid used to pickle the steel reportedly was disposed of directly into the quarry. Heavy metals were detected
in ground water downgradient from the quarry during a site investigation conducted by EPA in 1983.  Further
study identified low levels of numerous contaminants in the ground water.  Sediments and surface water within
the quarry contain VOCs and metals. Approximately 100 yd  of surface soil from the discharge ditch are
contaminated with  VOCs  and  metals.   The primary  contaminants  of concern affecting surface water,
sediments,  and soil are VOCs including toluene, and metals including chromium  and lead.

      The selected remedial action for this site includes:  excavation and offsite disposal in a RCRA landfill
of approximately 100 yd3 of contaminated surface soil from the pickle h'quor discharge ditch  and from along
the southern end of the quarry; implementation of a five-year monitoring plan  including a fish species survey
and fish tissue bioassay to  ensure absence  of  contaminants;  and ground water monitoring.  The estimated
present worth cost for this  remedial action  is $63,200. O&M costs were not provided.

PERFORMANCE STANDARDS  OR GOALS:  Waste pickle liquor is identified as RCRA waste K062, and
must meet the specified land disposal restrictions BDAT levels of chromium 0.094 mg/1 and lead 0.37 mg/1,
as measured in TCLP extract, prior to land disposal. Treatment of the soil at this site is  thought not to be
needed to meet the BDAT levels but the test will be performed prior to disposal to ensure compliance.

INSTITUTIONAL  CONTROLS:  Not applicable.
                                                B-95

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                      SOUTH ANDOVER, MN
                                        First Remedial Action
                                           March 30,  1988
ROD ABSTRACT
      The South Andover site is  comprised of several separate parcels of land totaling  approximately 50
acres in  the southern portion  of  Andover, Minnesota.   One-quarter mile to the north of the site  is a
residential neighborhood.  Further development is planned to the west and the  south of the site.  A large
portion of the site is buried under  a pile of tires and miscellaneous junk.  Several smaller pieces of property
on the site are auto salvage yards.  The Waste Disposal Engineering landfill, a Superfund National Priorities
List  site, is  located 3,000 feet northeast  of South Andover.  Multiple waste handling operations occurred
between  1954 and 1981 on several properties within the site  boundaries.  Consequently, (here are multiple
source areas which include a drum storage area, a waste discharge area, and a waste burning area.  In 1976,
citizen complaints of well contamination prompted the Minnesota Pollution  Control Agency (MPCA) to
investigate the site and issue a Citation of Violation  for the storage of chemical waste. Waste processing was
discontinued in early 1977, and waste acceptance ceased  in  1978.  In 1980, the MPCA issued  Notices of
Violation for improper disposal of  industrial wastes.  In 1981, the contents of approximately 700 drums were
disposed of by mixing them with waste oil and using the mixture  as fuel.  In 1986, a group of PRPs removed
approximately 500 additional onsite drums.   Soil investigations have been limited by the  presence of a large
volume of tires and junked automobiles piled onsite. The  majority of the tires are currently being shredded
and removed from the site.  A subsequent  RI/FS for soils and the lower sand aquifer is planned following
tire removal.  Currently, the primary  contaminants  of concern affecting the ground water  include:  arsenic,
chromium, lead, metals, VOCs, PCE,  TCE,  toluene, and organics.

      The selected remedial action for this site includes:  continuous ground water extraction and discharge
to surface water with pretreatment  as necessary; provision of municipal water to private well users on or near
the site;  ground water monitoring; and placement  of  restrictions on new  wells  on or near the site.  The
present worth cost for this remedial action ranges from $920,000 to  $2,460,000 depending on the discharge
option selected.  Present worth O&M  ranges from  $21,000 to $140,000.

PERFORMANCE STANDARDS OR GOALS:  The remedy will  meet MCLs by removing  the contaminated
ground  water in exceedance  of  MCLs.    Individual   goals  include:    1,1,1-trichloroethane  200  ug/1,
1,2-dichloroethylene 70 ug/1, ethylbenzene 680 ug/1, toluene 2,000 ug/1, xylene 440 ug/1, arsenic 50 ug/1, and
lead 20 ug/1.  PCE and  chromium will meet  the  State  Drinking Water Limit  of 6.9  ug/1 and 120 ug/1,
respectively.  The extraction well system will operate until the completion of the subsequent RI/FS, regardless
of future contaminant levels.  Final cleanup levels will  be  established  as part of the subsequent RI/FS.

INSTITUTIONAL CONTROLS: Restrictions will be placed on  new wells at or  near the site.
                                                 B-96

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     SUMMIT NATIONAL, OH
                                     First Remedial Action -  Final
                                            June 30,  1988
ROD ABSTRACT
      The 11.5-acre Summit National site is a former  coal strip mine in rural Deerfield Township, Portage
County, Ohio, approximately 45 miles southeast of Cleveland.  In the area immediately surrounding the site
there are  several residences, two landfills, a cement plant,  a rollerskating rink, and a used tire storage lot.
There are nine residential wells within 1,000 feet of the  site.  Summit National Liquid Services operated a
solvent recycling and waste disposal facility on the site  from 1973 to 1978.  Solvents, paint sludges, phenols,
cyanide, arsenic, and  other liquid wastes were  stored, incinerated, and buried or dumped during site
operations.  All onsite media are contaminated  with  a  variety of organic and inorganic compounds, and
investigations indicate that offsite areas also are affected. In addition, about 900 to 1,600 buried drums and
four buried tanks containing hazardous  substances have been identified  at the site.  In June 1978, EPA
ordered Summit National to stop receiving waste  materials and remove  all liquid  wastes from  the site. No
waste was removed before the owner sold the site  in March  1979.  Because hazardous chemicals were leaking
into the environment, in September 1979 EPA removed three  bulk tanks and their contents (approximately
7,500 gallons of hexachlorocyclopentadiene) and contaminated soil, and treated some contaminated  water.
Surface operations were conducted between November  1980  and June 1982,  during which EPA removed
drums, tanks, various  surface debris, and a small amount of contaminated  soil.   In  March 1987, EPA
performed an emergency action  to contain and  terminate  the actual or threatened release of hazardous
materials due to the  critically deteriorating condition of the ponds at the site. The primary contaminants of
concern affecting soil, sediments, ground water, and surface water are VOCs including benzene, toluene, TCE,
and xylenes, other organics including phenols, PAHs, and PCBs, and metals including arsenic and chromium.

      The selected remedial action for this site includes:  excavation and onsite incineration of approximately
32,000 yd  of contaminated soil and sediments and the contents  of approximately 1,600 buried drums and four
tanks, with disposal of incinerator residuals in an onsite RCRA landfill; ground water pump and treatment
and onsite surface water treatment using precipitation, flocculation, coagulation,  oil and water separation,
filtration, and carbon adsorption, and discharge of treated water to downgradient  surface water; installation
of a RCRA cap over the site, with regrading and revegetation; construction of a slurry wall around the site
perimeter; dismantling  and onsite disposal of all onsite structures; limited access and deed restrictions; ground
water and surface water monitoring;  and residence relocation.  The estimated present  worth  cost for this
action is $25,000,000  with annual O&M of $1,132,250.

PERFORMANCE  STANDARDS OR GOALS: Soil cleanup will attain a 2 x 10"5 cancer risk level.  Discharge
levels for  treated ground water and surface water will meet Federal and/or State water quality standards.
Individual  cleanup goals for  soil and ground water contaminants were not specified.

INSTITUTIONAL CONTROLS:  Deed restrictions will be implemented to control use of the property.
                                                B-97

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                          U.S. AVIEX, MI
                                    First Remedial Action -  Final
                                         September 7, 1988
ROD ABSTRACT
      The six-acre U.S. Aviex site is located in the City of Niles, Howard Township, Cass County, Michigan.
The site  lies in a residental neighborhood with single  family homes 100 feet to the south,  east, and north.
Because  there are no storm or sanitary sewers nearby, surface runoff from the site and surrounding areas
flows toward Bome-Huntly Drain, a  tributary of St. Joseph River, and ultimately Lake Michigan. U.S. Aviex
produced non-lubricating automotive fluids from the early 1960s until 1978.  During operations at the plant,
chlorinated hydrocarbons, including  trichloroethane (TCA), were released into the vadose zone south of the
process room.  The subsurface soil still contains significant quantities of TCA, TCE, and PCE.  In July 1972,
an underground pipeline containing diethyl ether was broken during excavation near the west wall of the
packaging room.  Over the next several years,  diethyl ether contamination was identified in downgradient
residential wells southwest of the plant, approximately one-half mile away. U.S. Aviex installed six monitoring
wells on  the site beginning in  1972  and also provided alternate water supplies to homes with contaminated
wells. In November 1978, a fire occurred on the site, and the large volumes of water used to extinguish the
fire flushed unknown amounts of chemicals contained in barrels and tanks into  the soil. Following the  fire,
chlorinated hydrocarbons were detected in domestic  wells.  Based on data developed during a ground water
investigation in 1982, a purge  and treatment system using air stripping  and discharge to surface water was
designed and installed to contain the contamination.   Contaminated ground water, however, is currently
flowing offsite to the southwest into residential areas. The primary contaminants of concern affecting soil and
ground water are VOCs including benzene, PCE, TCA, TCE, toluene, and xylenes.

      The selected  remedial  action  for this  site includes:  soil flushing  of approximately 11,500  yd3 of
contaminated onsite soil, and collection of onsite and offsite  ground water  and  fluids from the soil flushing
process, with treatment onsite  by air stripping and discharge to surface water.  The estimated present worth
cost for this remedial action in $3,024,000.

PERFORMANCE STANDARDS OR GOALS:   Ground water  target levels are  based  on MCLs,  proposed
MCLGs, and Federal or State water quality criteria.  Individual goals include benzene 5  ug/1 (MCL), toluene
2,000 mg/1 (PMCLG), xylenes 440 ug/1 (PMCLG), PCE 0.88 ug/1 (WQC), and TCE 5 ug/1 (MCL).

INSTITUTIONAL CONTROLS: Not  applicable.
                                                B-98

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    UNITED SCRAP LEAD, OH
                                    First Remedial Action - Final
                                          September 30,  1988
ROD ABSTRACT
      The United Scrap Lead (USL) site is located in a sparsely populated area  approximately one  mile
south of the  City of Troy, Concord Township, Miami County, Ohio.  The 25-acre site is bounded by two
residences, one combined commercial/residential unit, and one commercial establishment. The entire USL
site lies within the 100-year floodplain of the Great Miami River.  From 1946 to 1980, the site was used by
a lead reclamation business, reclaiming  lead from used automobile batteries and selling it to lead smelters.
The majority of the  site is currently  owned by Bailen Brothers, Inc., the successor organization to United
Scrap Lead, Inc.  The lead reclamation  operation involved the separation of the batteries from their casings
and tops, collection of the lead plates for reprocessing, and the disposal of the tops and casings onsite.  The
acid was originally discharged  directly  to an acid seepage field, but beginning  in late 1972, the acid was
neutralized with ammonia prior to discharge.  The site first came to the attention of authorities in June  1967
when USL requested a permit to continue to  dispose of the battery casings in  the back  portion  of the
property.  The request was granted, but  in 1972 the  Ohio Department of Health required USL to implement
a wastewater treatment program to fully neutralize the acid. Subsequent testing of the wastewater indicated
high levels of lead, cadmium, and  other toxic materials. In November 1985, the EPA  Region V Emergency
Response Section initiated an emergency removal action.  This action removed the contaminated soil and
waste materials from the immediate vicinity of the  surrounding residences  and placed them in a  large pile
onsite (approximately 55,000 yd ).   The areas of contamination  at the site include the waste pile and
underlying soil, contaminated site soil (approximately 45,000 yd  ), contaminated buildings, other miscellaneous
wastes,  approximately 100 empty drums, and several  partial or  intact  empty  chemical  storage  tanks.
Approximately 400 yd of sediment in a nearby tributary were found to contain high levels of lead and arsenic,
attributed to  surface runoff from the waste pile onsite. The primary contaminants of concern affecting the
soil and sediments include  lead and arsenic.

      The selected remedial action for this site includes:  excavation and onsite treatment of soil and battery
casings  by washing,  with lead recovery  and offsite disposal or recycling of casing residues, and replacement
of cleaned residual soil onsite;  excavation and dewatering of tributary sediments  followed by onsite disposal
with treated  soil; construction of a soil cover over  disposed material and revegetation; decontamination of
buildings and debris  followed by offsite disposal; installation of a new residential well; imposition of minimal
deed restrictions;  and groundwater and surface water monitoring. The estimated present worth cost for this
remedial action is $26,924,000 with estimated annual O&M costs of $55,375.

PERFORMANCE STANDARDS OR GOALS:  Onsite surface  soils  above 500 mg/kg lead will be  excavated
and treated to levels which render them non-EP toxic and leave them with less  than 500 mg/kg total lead.
Subsurface soils which are EP toxic will be excavated  and  treated to levels which render them non EP-toxic.
Sediment in the nearby  tributary will be excavated to background lead levels  (68 mg/kg).

INSTITUTIONAL CONTROLS:   Minimal deed  restrictions will be required, because no hazardous waste
will be left onsite. However, Miami County will zone the land use.
                                                B-99

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    VELSICOL CHEMICAL, IL
                                    First Remedial Action - Final
                                         September 30, 1988
ROD ABSTRACT
      The Velsicol Chemical Corporation (VCC) is a manufacturing facility located in east-central Illinois,
approximately one mile north of the  City of Marshall,  Clark  County,  Illinois.  The site is bordered by a
railroad on the south and by an unnamed tributary on the southwest.  A total of 334 acres onsite are leased
for crop farming. VCC was in operation between the mid-1930s and August 1987, and occupied an area of
approximately 420 acres, 172 of which were used for production or disposal practices for petroleum derivatives
including resins, solvents, and pesticides (including chlordane manufacturing). All process wastewater has been
deep-well injected onsite since 1965 and the majority of the waste solids and sludges generated at the facility
were disposed  of in a large  pond until  1980 when  the firm  ceased  pond  operations.  The plant  ceased
operations in 1987.  Accidental and intentional offsite releases of wastes were noted during the period  the
ponds were  in  operation.   In the 1980s, all  contaminated soil  and  visually contaminated sediments were
consolidated and stabilized with cement  and fly ash, and covered with a temporary clay cap and vegetation.
The primary contaminants of concern affecting the soil, sediments, surface water, and ground water are VOCs
including benzene and  other organics  including PAHs and pesticides.

      The selected remedial  action for this site includes:  excavation of 10,200 yd of contaminated  stream
and pond sediments and 87,900 yd of contaminated soil, backfilling with clay, and revegetation; consolidation
of all excavated material onsite in the large pond with  in-place stabilization followed by construction of a
RCRA cap; construction of ground water  collection drain with  disposal via onsite deep well injection, or
treatment using granular  activated carbon  prior  to offsite  discharge;   ground  water and surface water
monitoring; and implementation of land use and deed restrictions.  The estimated present worth  cost for this
remedial action including O&M is $9,080,910.

PERFORMANCE STANDARDS:   Ground water  and surface water collected from the trench system  will be
treated to achieve ACLs including benzene 2,000  ug/1; chlordane 0.0048 ug/1; carcinogenic PAHs 0.031 ug/1;
noncarcinogenic PAHs 5.4 ug/1; and phenols 100 ug/1.  Soil and sediment cleanup goals will attain ACLs
including benzene 2 mg/kg; chlordane 0.002 mg/kg; carcinogenic PAHs 0.010 mg/kg; non-carcinogenic PAHs
0.046 mg/kg; and phenols 100 mg/kg.

INSTITUTIONAL CONTROL:  Institutional controls including land use and deed restrictions will be provided
until the ground water has been cleaned  up to allowable levels.
                                                B-100

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                              WASTE DISPOSAL ENGINEERING, MN
                                     First Remedial Action - Final
                                          December 31, 1987
ROD ABSTRACT
      The Waste Disposal Engineering (WDE) site, consisting of 73 acres of a 114-acre dump, is located
in the City of Andover (formerly Grown Township), Anoka County, Minnesota.  The site area is characterized
by low relief with shallow water tables and numerous wetlands.  During the past year, extensive residential
development has been or will  be constructed  and planned for  around  the site.  The original dump was
established in 1963 and operated until 1968.  Disposal of wastes was by burial or burning in pits or trenches.
In 1968, WDE purchased the dump and was licensed by Grow Township  to operate as a sanitary landfill.
In 1970, WDE submitted a solid  waste permit application which  included a  proposal to build a specially
constructed  pit for hazardous waste disposal.  A permit was issued in March  1971 to operate the site as a
sanitary landfill.  The pit received approximately 6,600 containers (ranging  from one gallon pail to fifty-five
gallon drums) from 1972 to 1974, in the form of acids, caustics, waste paints, spent solvents, plating  sludges,
and cyanides.  An undetermined quantity of hazardous waste, much of it bulk loads, was disposed throughout
the landfill.  Of the 3,200,000 gallons of hazardous waste thought to be disposed at the site, only 10 percent
is thought to have been disposed of in the pit.  The area of refuse/non-hazardous waste disposal covers  an
area of 73 acres and contains approximately 2,500,000 yd  of waste.  Much  of the landfill is covered by lime
sludge.  The landfill  and pit have remained abandoned and inactive since February 1984.  The site property
has gone through tax forfeiture so that it is currently property of the State of Minnesota with  administration
by the county.  Currently, the pit area shows the most serious ground water degradation and is the dominant
source of contaminants entering Coon Creek.   The  primary  contaminants of concern include VOCs and
organics.

      The selected remedial action for this site includes: ground water pump and treatment using carbon
adsorption with offsite discharge to Coon Creek; installation of a RCRA cap to completely cover the 73-acre
landfill; installation of a clay slurry wall; implementation of institutional controls including well use restrictions;
filling in of  a wetland; construction of an  alternate wetland area;  and extensive monitoring.  The estimated
capital cost  for this remedial action is  $9,504,796 with present  worth O&M of $862,915.

PERFORMANCE STANDARDS OR GOALS:  The existing concentrations of contaminants in  Coon Creek
will be brought to below the 10  health-based  risk level and other freshwater  criteria established under the
Clean Water Act. The point of compliance will be set at the landfill boundary.  Safe Drinking Water Act
standards  are not ARAR since institutional controls will prevent use of the contaminant ground water.  Also,
MCLs have  not been established for site contaminants.

INSTITUTIONAL CONTROLS:  Well use will be prohibited onsite and  in adjoining areas.
                                                B-101

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                              ATCHISON/SANTA FE (CLOVIS), NM
                                    First Remedial Action - Final
                                         September 23, 1988
ROD ABSTRACT
      The Atchison/Santa Fe (Clovis)  site  is located just south  of the Atchison, Topeka, and  Santa Fe
(ATSF) Railway switching yard in Clovis, New Mexico.  The site is  comprised of an approximately 26-acre
playa lake (Santa Fe Lake) which has been owned by ATSF since the early 1900s.  The surrounding area is
mostly industrial, and the lake is currently fenced off to  public access.  The lake was used for the disposal
of wastewater from various operations throughout the years.  Wastewater from the washing of hopper cars
used for hauling potash, cement, fertilizer, grain, and coke were disposed in the  lake from 1962 to  1982.
EPA and ATSF reached an agreement under an Administrative Order on Consent for ATSF to conduct an
investigation of the lake area.  The investigation included sampling of the lake water, the sediments at the
bottom of the lake, the soils between the lake bottom and the water table, and the ground water underlying
the lake.  The major concern at  this site is the potential threat to ground water.  The aquifer that extends
under the lake is the source of drinking water for the City of Clovis.  Although contamination of the ground
water does not pose a current threat to the city water supply,  it does indicate that migration of contaminants
from the lake is possible if the source of contamination is not removed. The primary contaminants of concern
affecting the  sediments, soil, surface  water, and ground water are  metals including arsenic, chromium, and
lead, organics including phenols,  and inorganics.

      The selected remedial  action for  this  site includes:  construction of a run-on  control dike  and ditch
system;  evaporation of the  water in Santa  Fe Lake through a pump and spray sprinkler system; excavation
and onsite treatment of the lake sediments through biodegradation;  in situ biodegradation of contaminated
soil followed  by  excavation  and placement  in the land treatment area; capping the  land treatment  area with
a PVC liner and vegetated  soil layer; grading and revegetation of the disturbed area; access restrictions; and
ground water and land treatment  area monitoring. Additional  action may be taken to remediate ground water
contamination if subsequent monitoring results indicate the need for action. The estimated present worth cost
for this remedial action is $2,840,000.

PERFORMANCE STANDARDS  OR GOALS:   The selected remedy is aimed at preventing contamination
of the aquifer and will meet all primary State and Federal standards for drinking water.

INSTITUTIONAL CONTROLS:   ATSF will be  prohibited from installing drinking water wells within site
boundaries.
                                               B-102

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  BAILEY WASTE DISPOSAL, TX
                                    First Remedial Action  - Final
                                            June 28, 1988
ROD ABSTRACT
      The Bailey Waste Disposal site is an inactive industrial waste facility located approximately three miles
southwest of Bridge City,  Orange  County,  Texas.   The  site is  part of a  saltwater marshland near  the
confluence of the Neckes River and Sabine Lake, and lies within the 100-year floodplain.  The site occupies
approximately 280 acres and includes two rectangular ponds (A and B)  constructed by dredging the marsh
and piling the sediments to form levees.  The ponds were constructed in  the mid-1950s as  part of the Bailey
Fish Camp, which operated until the  1960s.  Industrial wastes, primarily organics, were disposed of along the
north and east margins of Pond A during the 1950s and 1960s. Four separate areas of contamination in the
vicinity of the  ponds have been  identified.  They include:   a waste channel, located north of Pond A that
contains a minimum of 44,000 yd of industrial waste and debris; an area east of Pond A containing 21,000
yd  of municipal and industrial waste; a drum disposal area south  of Pond A containing 58 corroded drums
with an estimated volume of 80 yd of industrial waste; and  a series of waste pits, north of Pond A and west
of the waste channel, containing  1900 yd  of  tar-like wastes.  The primary contaminants of concern affecting
the sediments include: VOCs including benzene and toluene, aromatic and chlorinated hydrocarbons, organics
including PAHs, and metals.

      The selected  remedial  action for this site includes:   relocation, consolidation, and  treatment  of
contaminated sediments and wastes  using a solidification  technique developed  during design, followed by
onsite disposal and capping of the residual matrix.  The estimated present worth for this remedial action is
$13,700,000.

PERFORMANCE STANDARDS  OR GOALS:  Because ARARs exist  at this site for contaminated soil and
sediments no chemical specific ARARs are available. The lifetime risk attained for the direct contact scenario
for an adult exposed to the maximum concentration of contaminants found at the site will be 9 x 10   and
for a child it is 1.2 x 10"5.

INSTITUTIONAL CONTROLS:   Not applicable.
                                               B-103

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                        BRIO REFINING, TX
                                    First Remedial Action -  Final
                                           March 31, 1988
ROD ABSTRACT
      The 58-acre  Brio Refining site is located in Harris County, Texas, approximately 20 miles southeast
of Houston.  The site is broken into two parcels, 49-acre Brio North and 9-acre Brio  South, separated by
Drive Farm Road.  The site is bordered by Mud Gully, a flood control ditch that drains into Clear Creek,
Dixie Oil Processors NPL site, Friendswood oil field, and the Southbend residential  subdivision.  Between
1957 and 1982, the site refined crude oil and styrene tars to produce toluene, ethylbenzene, aromatic solvents,
naphthalene, diesel fuel, and kerosene.  Various owners of the site stored styrene tars in  24 open pits.  Other
waste products and sludges  were stored  in aboveground tanks.  Site investigation  indicate  that between
500,000  to 700,000 yd  of onsite soil have measurable contamination, and that high levels of VOCs exist in
ground water underlying the  site.  Primary contaminants of concern  affecting the soil  and ground water are
VOCs including 1,2-dichloroethane, 1,1,2-trichloroethane, and methylene chloride; and base/neutral organic
compounds  including phenanthrene and fluoranthene.

      The  selected remedial action for the Brio Refining site includes:   excavation  and incineration or
biological treatment of all onsite soils, sludges, and  liquids found to be  above action levels defined  in the
Endangerment Assessment, with backfilling of all treated material passing the Toxicity Characteristic Leaching
Procedure (TCLP).  If the Brio Site Task Force (PRPs) can successfully  demonstrate  the effectiveness of
aqueous-phase biological treatment such treatment will be considered; otherwise, incineration will be selected.
Also included are:  excavation and treatment of all visual onsite  seeps; excavation and removal of all  offsite
soils contaminated above background levels; further investigation of Pit G to locate sludge or  contaminated
soil underlying the existing onsite wastewater treatment impoundment; consolidation and disposal of all inert
debris and rubble with ultimate disposition to be determined during remedial design; disposition of Mud Gully,
the flood control ditch, to be determined  during remedial design; in-place stabilization of wastes existing in
the wastewater treatment impoundments,  backfilling  with dike materials,  capping, regrading, and vegetating
to improve  runoff,  and installation of a  package wastewater treatment system or routing wastewater to a
POTW; removal and offsite disposal of tank contents, and decontamination,  dismantling,  and selling or  offsite
disposal of tanks; dismantling of all onsite process equipment; monitoring ambient air; control of air emission
from  the  treatment processes; venting waste enclosures to an emission control device; treatment of ground
water in the Numerous Sand Channel Zone to a level to be determined in design; natural attenuation  of the
Fifty-Foot Sand Aquifer with monitoring  to ensure effectiveness; regrading  and vegetating  areas outside
excavation boundaries; construction of a stormwater transmission  system  draining to Mud  Gully;  and
imposition of  deed  restrictions as  necessary.  The estimated present worth cost of this remedial action is
$23,308,000-$23,333,000 for biological treatment or $22,458,000-$26,598,000  for incineration based on  62,900
yd3 of treatable material.

PERFORMANCE STANDARDS OR GOALS:  Media above Endangerment Assessment  action levels will be
treated to target levels based  on a 10"  incremental cancer risk for carcinogens, and on an acceptable chronic
daily  intake for  non-carcinogens.    Individual  action and  target  levels  were not  specified.   Offsite soil
contamination above unspecified background levels will be  removed.   Ground water in  the channel will be
treated to a level determined during design.  Since the ground water may never be used as a  ground water
source,  immediate application of MCLs is not appropriate.

INSTITUTIONAL CONTROLS:  Deed restrictions will be implemented as needed.
                                                B-104

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                          DIXIE OIL, TX
                                        First Remedial Action
                                           March 31, 1988
ROD ABSTRACT
      The 26.6-acre Dixie Oil Processors (DOP) site is located in Harris County, Texas, approximately 20
miles southeast of Houston.  The site is broken into two parcels, 19-acre DOP North and 7.6-acre DOP
South, separated by Dixie Farm Road. The site is bordered by Mud Gully, a flood control ditch that flows
into Clear Creek, Friendswood Oil Field, the Brio Oil Refining NPL site, and various athletic fields. Between
1969 and 1978, the DOP North parcel operated as a copper  recovery and hydrocarbon washing facility.  Six
surface impoundments were used  to store copper wastewater, and wastewater from the hydrocarbon washing
operation prior to recovery and treatment.  In 1977 the impoundments were closed and decommissioned and
the property sold to DOP.  In 1978, DOP began operations on the South parcel of the site.  These activities
included  the  following:  regeneration of  cuprous  chloride  catalyst; hydrocarbon washing  to  produce
ethylbenzene, toluene, aromatic solvents, and styrene pitch; oil recovery; and blending and distilling chemical
residues to produce fuel oil, creosote extender, and molybdenum concentrate catalyst. The North parcel was
not used in these operations.  All site activities ceased hi 1986. Wastes were  disposed of onsite in tanks,
drums, and waste pits. Sampling  indicates contamination of surface and subsurface soils and shallow ground
water.   The  primary  contaminants  of  concern  affecting  soil  and  ground  water  are  ethylbenzene,
hexachlorobenzene, copper, 1,1,2-trichloroethane, and methylene chloride.

      The selected remedial  action for the Dixie Oil Processors site is a limited action alternative consisting
of:  site controls including, but not limited to, fencing and deed restrictions to prevent site access; excavation
and removal of contaminated  offsite soils to background levels, the extent of removal to be determined during
remedial design; consolidation and disposal of onsite debris  and rubble, disposal method to be determined
during design; remediation of Mud Gully, details to be determined during design; operation of the  existing
wastewater treatment system  during implementation of remedial action, then dismantling and removal upon
completion; removal and disposal  of tank contents and drums,  and dismantling,  decontamination, and either
selling or offsite disposal of tanks; dismantling and disposal of all process equipment; ambient air sampling;
control of  air emissions from treatment processes, if necessary; sampling and monitoring of Mud Gully
sediments and ground water to determine effectiveness of remedy; and regrading and vegetation of the entire
DOP site.  The estimated present worth costs of this remedy is $241,000.

PERFORMANCE STANDARDS OR GOALS:  Excavation of offsite  contaminated soil to background levels.

INSTITUTIONAL  CONTROLS:    Deed   restrictions will  be  implemented  to  prevent  site  access  and
development.
                                                B-105

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                      FRENCH LIMITED, TX
                                    First Remedial Action  - Final
                                          March 24, 1988
ROD ABSTRACT
      The French Limited, Inc., (FLI) site, a 22.5-acre tract of land, is located in Harris County, Texas. The
site is situated one mile east of the San Jacinto River.  The entire site is within the 100-year flood plain of
the River and has flooded frequently in the past.   Between 1966 and  1972, approximately 300,000 yd3 of
industrial wastes from area petrochemical companies were deposited in  an  unlined 7.3-acre pit, formerly an
active sand pit.  The  disposal  site operated under  a temporary permit  issued by the Texas Water Quality
Board.  In 1973, the permit was revoked after extensive public hearings  and legal proceedings, and FLI was
ordered  to cease operations.  As part  of the settlement, FLI  was ordered to remove  all the structures,
tankage,  and process equipment.  The tract of land was ultimately deeded to the State.  During a flood event,
the dike  surrounding the waste pit was overtopped and breached, and contaminated sludges were discharged
into an adjacent slough. In 1982,  the U.S. EPA conducted an immediate Removal Action (IRA). The dike
was repaired and the majority of discharged sludges  were pumped back into the pit.  The  floating portion of
the sludges was removed and disposed of in July 1983 during another U.S. EPA IRA.   Ground water has
been heavily contaminated by the leaching action of organic wastes deposited in the pit. Sludge and soil from
the waste pit and adjacent slough  include the following primary contaminants:  PCBs, PCP, organics, VOCs,
metals, and arsenic.

      The selected remedial action for this site includes: in-situ biodegradation of sludges and contaminated
soils with aeration of the  lagoon  waste  for degradation enhancement; stabilization of residues followed by
on-site disposal; ground water  pump and treatment; surface water discharge to the San  Jacinto River with
treatment, as necessary; backfilling of the lagoon to  grade  and contour;  and ground water monitoring. The
estimated present worth for  this remedial action  is $47,000,000.

PERFORMANCE STANDARDS  OR GOALS:   Ground water  recovery and treatment  will  continue until
modeling shows that  a reduction  in  the concentration of VOCs to a level which attains  the 10"  human
health criteria can be achieved through natural attenuation in ten years or less. Additionally, remediation will
be consistent with TSCA regulations and policy for cleanup of PCBs and PCB contaminated material,  Water
Quality Criteria for ground water and surface water, including criteria established in the SDWA and its MCLs.
Individual cleanup goals were not specified.

INSTITUTIONAL CONTROLS:   Not applicable.
                                                B-106

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                         GURLEY PIT, AR
                                   Second Remedial Action - Final
                                         September  26, 1988
ROD ABSTRACT
      The Gurley Pit site consists of a 3.25-acre pit located  approximately one mile north of Edmondson,
Crittenden County, Arkansas.  The site lies within the  100-year flood plain of Fifteen Mile Bayou, which
discharges to the Mississippi River.  Land in the vicinity  of the site is sparsely populated with five residences
located within a one-half mile radius. The primary land use is agricultural. Gurley Refining Company (GRC)
leased the site from RA. Caldwell between 1970 and 1980.  During this time the pit was divided by levees
into three cells and used between 1970 and 1975 as a state permitted disposal site for secondary oil refining
wastes including acids, oil sludges, PCBs, inorganics, and spent diatomaceous wastes. In March 1975, citizen
complaints regarding discharges from the pit led to investigations by the Arkansas Department of Pollution
Control and Ecology (ADPCE), which discovered permit and State environmental statute violations by GRC.
GRC abandoned the site in 1976. In May 1978, EPA and ADPCE received complaints of chronic overflows
from storm runoff.  These overflows had an adverse affect on fish and waterfowl in the Fifteen Mile Bayou.
Subsequently, EPA conducted separate spill cleanup operations in July 1978 and April 1979.  EPA completed
an Enforcement Decision Document (EDD) in October 1986, which addressed the source control operable
unit consisting of the waste in the pits and the surface contamination.  The selected source control remedy
included treatment and discharge of on-site surface water,  off-site incineration of PCB-contaminated oil,
ground water monitoring and stabilization,  and on-site disposal of contaminated sludge, sediment, and soil.
This ROD addresses the ground water operable unit.  Investigations have determined that contaminants from
the pit  have not  migrated through the subsurface into  the  ground water.   Elevated  levels of inorganics
(specifically arsenic and manganese) were detected but were consistent with background levels.  No site-related
contaminants were identified in the  ground water.

      The selected remedial action for this site is no further action beyond that already  specified in the
source control operable unit EDD.  The ground water will be monitored for at least thirty years to ensure
that no  migration of the contaminants occurs.  There are no Federal capital or O&M costs associated with
this remedial action.

PERFORMANCE STANDARDS  OR GOALS:  Concentrations  of metals (e.g., arsenic, iron, and manganese)
that exceeded MCLs in ground water were  not  attributable to the pit contaminants but exist in elevated levels
naturally; therefore, ground water cleanup  levels are not applicable for this site.

INSTITUTIONAL CONTROLS:   Not applicable.
                                               B-107

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                      Progress Toward Implementing Superfund:  Fiscal Year 1988
                               INDUSTRIAL WASTE CONTROL, AR
                                     First Remedial Action - Final
                                            June 28, 1988
ROD ABSTRACT
      The eight-acre Industrial Waste Control (IWC) site, an abandoned coal strip mine, is a closed industrial
waste landfill about  eight miles southeast  of Fort Smith  near  Jenny Lind,  Sebastian County, Arkansas.
Landfilling operations began in the late 1960s or early 1970s and primarily dealt with municipal refuse and
debris and industrial trash.   In August  1974, the  site  was purchased by Grady  Shipley  and granted an
industrial landfill permit by the Arkansas Department of Pollution and Ecology.  The site  received a wide
variety of liquid wastes (including methylene chloride, phenols, cresylic acid, and paints), solid wastes, and
sludges.   In  addition,  the site  possibly contains about 9,000  buried  drums.   In March  1977,  surface
impoundments overflowed and contaminated a local pond and pastures north of the site resulting in a fish
kill hi the pond and the death of several cattle. Consequently, the site was covered, recontoured, and closed
by the State in 1978.  Land use around the site primarily consists of pasture land and low density residential
areas. Although no residences within a one-half mile radius north of the site depend on private wells for
drinking water, several local wells are still used for watering lawns  and livestock, a fish pond, and occassionally
for domestic uses when the municipal supply is not functional.  Four  areas of contamination  have been
identified at the site.  Area A is the  deepest portion of  the strip mine which ran along the entire northern
portion  of the site, and includes drums containing solidified wastes typically of dried paint and solidified foam.
Area B  lies south of the strip mine and includes shale spoils  from  surface mining and random crushed drums.
Area C is located in the center of the  site and contains two former surface impoundments constructed in 1975
and used as evaporation ponds  for  bulk liquids.   Shale spoils, crushed  used  drums, landfill debris, and
sludge-like sediments were also found in Area C.  Area  D, located in the extreme southwest corner south
of Area B, contains intact, liquid-filled and crushed drums as well as contaminated shale spoil.  Approximately
19,500 cubic yards of contaminated soil is located  in Area C and D.  The  primary  contaminants of concern
affecting the  soils, sediments, ground water, and  surface water include:  VOCs  including toluene, organics,
and metals including  arsenic, chromium, and lead.

      The selected remedial action for this site includes:  installation of a french drain along the south, west,
and east sides of the site with a synthetic liner or other barrier, such as a slurry wall installed on the site side
of the french drain; excavation of Area D liquid-filled  drums with off-site disposal;  excavation and on-site
stabilization of Areas C and D soil with on-site disposal of residual  matrix in  the Area C excavation  pit;
categorization of solid and liquid wastes resulting from previous  investigations with disposal consistent  with
Area C and D materials; ground water pump  for off-site treatment, mixture with the contaminated soil and
stabilized on-site, or treatment in an on-site facility with discharge to be determined  during design; multilayer
RCRA  capping to  cover the area bound by the french drain system and  the northern site border; surface
water diversion using ditches and berms;  access  and  land  use restrictions; and  ground water  and  site
monitoring. The estimated present worth cost for this remedial  action is $11,400,000.

PERFORMANCE  STANDARDS  OR  GOALS:    The  stabilized  matrix  will  pass  the RCRA  Toxicity
Characteristic Leaching Procedure and/or other EPA-approved leachate test as  well as the ASTM strength
test.  Ground water plant discharge and effluent limitations  will be established by EPA and ADPCE.  MCLs
for arsenic, cadmium, chromium, lead, and TCE are relevant  and appropriate ground water cleanup standards;
however, the quantitative MCL goals  were not specified.

INSTITUTIONAL CONTROLS:  Land use restrictions will  be implemented to maintain the integrity of the
Remedial Action and to prevent further on-site development.
                                                B-108

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    KOPPERS TEXARKANA, TX
                                        First Remedial Action
                                         September 23, 1988
ROD ABSTRACT
      The Koppers Texarkana site is located within the City of Texarkana, Texas.  The site consists of a
34-acre residential area and a 28-acre former sand and gravel operation.  The site is bordered by the Texas
and Pacific Railroad to the north,  an unnamed creek to the northwest, Wagner Creek to the southwest,
Jameson Street to the south, and a drainage ditch to the southwest.  The entire site is within a 100-year flood
plain.  The  Koppers Company operated the site  as a wood preserving facility from 1910  to 1961, using
pentachlorophenol (PCP), creosote, and metallic salts in the operation. The facility consisted of an operations
area, a drip track, and treated and untreated wood storage areas.  The  site is currently owned by Carver
Terrace, Inc., which built a subdivision of 79 single-family homes on a portion of the site, and the Kennedy
Sand and  Gravel Company, which mined sand and gravel on their parcel from 1975 to 1984.  Two other
owners of small portions of the site are the Mount Zion Missionary Baptist Church and Jesse and Otha Pace.
The Texas Department of Water Resources (TDWR) became aware of the site in 1979 through the Ekhardt
Survey.  The sand and gravel pit was fenced off, and in 1985 EPA covered 24 residential lots with soil  and
sod to protect the residents while the RI/FS was  conducted by  Koppers under an Administrative Order on
Consent.  The RI indicated that the highest concentration of site contaminants in the soil were located near
the operations and drip track areas of the old wood preserving facility. In addition, the highest concentrations
in the ground water were noted in or near pockets of non-aqueous phase liquids (NAPLs) also in these  site
areas.  The primary contaminants  of concern  affecting  the soil,  ground water, and sediments are  VOCs
including benzene, xylenes, and toluene, other organics including PAHs and PCP, and metals including arsenic.

      The selected remedial action for this site includes:  excavation of approximately 3,300-19,400 yd  of
soil from residential yards where CPAH levels exceed 100 mg/kg, with backfilling using clean soil, landscaping
disturbed yards, and on-site treatment of the soil using soil washing, with  disposal in the  Kennedy Sand  and
Gravel pit or an off-site hazardous waste  disposal facility;  temporary relocation of sensitive residents (if
necessary); collection of NAPLs via  trenches in the Kennedy Sand and Gravel pit and/or via a well nest in
Carver Terrace, and treatment at an on-site waste water treatment plant using oil/water separation followed
by activated  carbon or fluidized carbon bed treatment, with recycling or off-site incineration of recovered
NAPLs and  reinjection of treated ground water into the aquifer; ground water monitoring; excavation  and
treatment  of drainage ditch sediments  in the  soil washing unit; and deed and access restrictions.  The
estimated  present worth cost for this remedial action is $6,400,000,  which includes annual O&M  costs of
$300,000.

PERFORMANCE STANDARDS  OR GOALS:   The cleanup  goal  for  contaminated soil  is 100  mg/kg
carcinogenic PAHs,  corresponding  to a  risk factor of 3 x 10   .  The ground  water levels of free phase
creosote will be remediated to a level of nondetection.

INSTITUTIONAL CONTROLS:  Deed notices will be imposed  for the Kennedy Sand and Gravel  property.
                                               B-109

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                NORTH CAVALCADE STREET, TX
                                    First Remedial Action - Final
                                           June 28, 1988
ROD ABSTRACT
      The 21-acre North Cavalcade Street site is located in northeast Houston, Texas. The surrounding areas
are a mixture  of  residential,  commercial,  and industrial properties.   Surface water  is drained by  three
stormwater drainage ditches, one of which flows into Hunting Bayou, a limited aquatic habitat as classified
by Texas Water Quality Standards.  The site was developed in 1946 when Houston Creosoting Company, Inc.,
(HCCI) established creosote wood preserving operations.  Around 1955, HCCI added pentachlorophenol
(PCP) wood preservation services and other support facilities.  Wood preserving operations ceased in 1961,
and the property was sold in 1964.  Subsequent property owners divided the site into smaller tracts and sold
them  to  a succession of owners.   There has been no  industrial activity at this site since  1964.  Between
September 1985 and November 1987, EPA sampled all environmental media and found PAHs, VOCs, and
components of creosote in soil, ground water, and sediments.  The area of soil  contamination corresponds
to where creosote was historically stored,  and the point of entry for  the contaminants into the ground water.
The plume of contamination currently covers approximately four acres. Creosote components were found in
drainage ditch sediments probably as a result of rainfall runoff during  the time of historical operations. The
primary contaminants of concern affecting the ground water, soils, and sediments include:  VOCs, benzene,
toluene, xylene, and PAHs.

      The selected remedial action for this site includes: biological treatment of 22,300 yd  of soil (in situ
is preferred, however, the optimum method will be determined after pilot testing); ground water pump and
treatment of 5,600,000 gallons using oil/water separation and  carbon adsorption with  re-injection into  the
aquifer, or, if necessary to maintain  the water balance, discharge  into an on-site drainage ditch which
discharges into Hunting Bayou; and off-site incineration of all non-aqueous phase liquids (NAPLs) separated
out from the ground water.  The estimated present worth cost for this remedial action  is $4,210,000.  There
is no  O&M associated with this remedy.

PERFORMANCE STANDARDS  OR GOALS:  Soil and  ground water cleanup will attain a cumulative 10~5
cancer risk level.  Individual soil  cleanup  goals include PAHs 1 mg/kg and benzene 0.04 mg/kg.  Individual
goals  for ground  water include:   benzene  5 ug/1  (MCL),  toluene  2,000  ug/1,  and xylene 440  ug/1.
Additionally, ground water will be  treated until all NAPHs are completely removed.

INSTITUTIONAL  CONTROLS:  Not applicable.
                                               fc-110

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   ODESSA CHROMIUM I, TX
                                   Second Remedial Action - Final
                                           March 18, 1988
ROD ABSTRACT
      The Odessa Chromium I site consists of a series of chromium-contaminated wells within 300 acres of
residential, commercial, and industrial properties and facilities immediately west of West County Road, just
outside the northwestern  city limits of Odessa, Ector County, Texas. Nearly every residence or commercial
facility is served by one or more water wells  completed in the underlying Trinity Aquifer, which offers the
only source of potable ground water. Two potential sources of ground water contamination at the site have
been identified:  4318 Brazos property and 2104 West 42nd Street. In December 1979, the Texas Department
of Water Resources identified the 4318 Brazos  property as a potential source of chromium contamination.
Several chrome plating operations functioned at this property between 1972 and 1977. The site at 2104 West
42nd Street is presently operating as a metal plating facility.  This property was first identified as a possible
source of ground water contamination in 1978.  The first operable unit ROD, signed in  September 1986,
provided for  the extension  of the  city's water supply until final  ground  water  remediation is complete.
Although chromium is the primary contaminant of concern affecting the ground  water, other inorganics have
been found in the soil.

      The selected remedial action for this  site includes:  demolition and disposal of a  building at 4318
Brazos; ground water pump and treatment using electrochemical techniques with reinjection into the Trinity
Aquifer;  and  ground  water monitoring.   The  estimated present  worth  cost  for  this  remedial action is
$2,836,000.

PERFORMANCE STANDARDS  OR GOALS: The EPA Primary Drinking Water Standard  for chromium
0.05 mg/1 was used as the basis for  the target concentration.  This MCL standard is currently under review
by EPA. Should the standard be revised prior to implementing the design phase  of the project, the revised
standard will become the  target concentration. The risk associated with the ingestion of chromium in the soil
approaches the 10  risk  level; therefore, soil  remediation is not considered necessary.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-lll

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   ODESSA CHROMIUM II, TX
                                   Second Remedial Action - Final
                                          March 18,  1988
ROD ABSTRACT
      The Odessa Chromium II site consists of a series of chromium-contaminated wells within 200 acres
of residential, commercial, and industrial properties and facilities just outside the northwestern city limits of
Odessa, Ector County, Texas.  Nearly every residence or commercial facility is served by one or more water
wells completed in the underlying Trinity Aquifer, which offers the only source of potable ground water.  Two
separate contaminant plumes are bounded by the site:  5329 Andrews Highway and 57th Street and Andrews
Highway.  In 1970, local health department authorities investigated a complaint of contaminated well water
(5.5 mg/1 chromium)  on the property to the south of 5329 Andrews  Highway.  At that time, wastewater
analysis did not indicate the presence of chromium, but in 1978, a cleaning vat solution,  which was eventually
stored in  partially buried steel tanks, contained 2.8 mg/I of chromium.   One of the  storage  tanks was
discovered leaking and the tanks were subsequently removed.   The  facility  at 57th  Street and Andrews
Highway has been in operation since about 1950. Chromates were utilized in the cooling system until about
1976.  This system was apparently tied into one of the plant's water wells and during occasional slow downs,
cooling  water could have been inadvertently back flushed into the well  since there was  no check valve.  The
plant also utilized an unlined pit for the disposal of contaminated wastewater, including chromate wastes from
the cooling water system, until about 1977.  The first operable unit, signed in September 1986, provided for
the extension of the city's water supply  until final ground water remediation is complete.  Although  chromium
is the primary contaminant of concern to  the ground water, other inorganics have been found in  the soil.

      The selected  remedial action  for  this site  includes:   ground water pump  and  treatment using
electrochemical techniques with reinjection into the  Trinity  Aquifer and  ground water  monitoring.   A
treatability study  will be  conducted during  the system  design phase of the project to aid in designing  an
appropriate treatment system.  The  estimated present worth cost for this  remedial action is $3,618,000.

PERFORMANCE STANDARDS OR GOALS:  The EPA Primary Drinking Water Standard for  chromium
0.05 mg/1 was used as the basis for the target concentration.  This MCL standard is currently under review
by EPA.  Should the standard be revised prior to  implementation of the design phase  of the project, the
revised  standard will become the  target concentration.  The risk  associated with the ingestion of  chromium
in the soil approaches the 10   risk level; therefore, soil remediation is not  considered necessary.

INSTITUTIONAL CONTROLS:  Not  applicable.
                                               B-112

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                OLD MIDLAND PRODUCTS, AR
                                   First Remedial Action - Final
                                          March 24, 1988
ROD ABSTRACT
      The Old Midland Products site is an abandoned creosote and pentachlorophenol wood preserving plant
and sawmill located in Ola, Yell County, Arkansas.  The site is flat with a total area of approximately 37
acres.  Between 1969 and 1970, Old  Midland Products treated wood  with creosote.  Effluents  from the
treatment process containing PCP and polynuclear aromatic compounds were discharged into lagoons via a
moveable discharge pipe.   Pond overflows  of minor consequence have  occurred with  drainage  to the
intermittent stream west of the lagoons. The  land, originally owned by the Old Midland Products Company,
was sold  in 1979 to the Plainview - Ola Economic Trust, Inc.  Approximately 9,000 to 21,000 yd3 of soil, 850
yd  of drainage sediments, 450,000 gallons of ground water, 620,000 gallons of lagoon fluids, and  2,770 yd
of lagoon sludges are  contaminated with PCP and polynuclear aromatic hydrocarbons.

      The selected remedial action  for this site includes:  on-site thermal destruction of the contaminated
surface soils, lagoon sludges, and drainageway sediments, with on-site disposal  of waste residuals and a
vegetated cover and ground water pump, and treatment using carbon adsorption, possibly with biodegradation
pretreatment.  The estimated cost for this remedial action is $12,000,000.

PERFORMANCE STANDARDS OR GOALS:  The cleanup level for total pentachlorojphenol (PCP) contained
in soil, sludges, and sediments  is 1 mg/kg.  Ground water cleanup will attain a 10  cancer risk level.

INSTITUTIONAL CONTROLS:  Not applicable.
                                              B-113

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                       SAND SPRINGS, OK
                                      Second Remedial Action
                                           June 28,  1988
ROD ABSTRACT
      The 235-acre Sand Springs Petrochemical site, located in Sand Springs, Oklahoma, is a former refinery
and solvent recycling facility that operated between 1900 and the early 1970s.  The site is located immediately
west of Tulsa  along the northern bank of the Arkansas River and consists of unlined  acid sludge pits, a
surface impoundment, solvent and waste oil lagoons, and  several  subsurface sludge pits and spray ponds.
During plant operations, waste products were disposed of in the unlined pits, surface impoundments, and spray
ponds. Primary contaminants of concern affecting the soils, shallow ground water, and sediments were organic
solvents and heavy metals.  In September, 1987, a source control Record of Decision was signed to control
and destroy the major sources of contamination.  This  second Record of Decision deals with the remainder
of the site, primarily shallow ground water and minimally contaminated  soil.

      The selected remedial action for the remainder  of the Sand Springs  site is no further action. Based
upon  the findings  of the RI/FS,  the Endangerment Assessment for  the operable unit  concluded that no
significant risk to public health or the environment exists.  Ground water and the Arkansas River water will
be monitored  for 30 years  after completion  of the source control remedial action, and warning signs and
fences will be  erected as  part of this no action alternative.  Estimated capital cost of  the remedy  is $9,300
with annual O&M costs of  $45,600.

PERFORMANCE STANDARDS OR GOALS:  The ROD did not  specify individual goals; however, nearby
residential wells have not been  affected and  should not become affected based on the direction of ground
water flow, which is towards the river. In a worst case scenario, discharge  from the site to the river would
be 4.6 times less than NPDES regulatory standards.

INSTITUTIONAL  CONTROLS:  Site access  restrictions will be implemented.
                                               B-114

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                          SOL LYNN, TX
                                       First Remedial Action
                                          March 25, 1988
ROD ABSTRACT
      The 0.75 acre Sol Lynn site, also known as the  Industrial Transformers site, is located in Houston,
Texas.  The area  around the  site is  a mix  of residential, commercial,  and light  industrial facilities.
Approximately 2,000 residents and 100,000 other people move within a one-mile radius of the site on a daily
basis due  to recreational activities associated with the area. The site operated as an electrical transformer
salvage and recycling company between 1971 and 1978 and as a chemical recycling and supply company from
1979 through 1980.  The first documented investigation of  this site  took place during the fall of  1971 when
the City of Houston Water Pollution Control Division noted that workers at Industrial Transformers poured
oil out of electrical transformers onto the ground during  transformer dismantling.  In 1981, strong odors
originating from the site were brought to the attention of the Texas Department of Water Resources, the
predecessor agency of the Texas Water Commission (TWC). Upon inspection, approximately 75 drums were
found scattered about the property.  Most of the drums,  labeled "trichloroethylene", were empty and had
puncture holes. A technical assessment of the site, commencing in January 1986, indicated the presence of
PCB contamination.  PCB contamination has  been confined to the  top two feet of soil.   The  highest
concentrations of PCBs were found in the middle of the site. TCE  has migrated deeper than the PCBs and
away from the  site.  Residual TCE remaining in the  surface soil will be  remediated  along with the PCB
contaminated soils.   Any TCE  that has migrated into  the deeper  ground water will  be addressed in the
subsequent remedial action.  The primary contaminants of concern  affecting the soil are PCBs.

      The selected  remedial  action  for this site  includes:   excavation  of approximately  2,400  yd  of
PCB-contaminated soil and treatment using alkali metal polyethylene glycolate (APEG) complex dechlorination
with on-site disposal of  treatment residuals; effectiveness verification of the dechlorination process through
treatability studies; and pretreatment of liquid  by-products, if necessary, with discharge into a publicly owned
treatment works facility.  The estimated present worth cost for this  remedial  action is $2,200,000.

PERFORMANCE STANDARDS OR GOALS:  Soil will be treated at or below  the health-based criterion
for PCB-contaminated soils of 25 mg/kg based on the Toxic Substances Control Act Spill Cleanup Policy.

INSTITUTIONAL CONTROLS:  Not  applicable.
                                               B-115

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                          SOL LYNN, TX
                                   Second Remedial Action - Final
                                         September 23, 1988
ROD ABSTRACT
      The 0.75 acre Sol Lynn site, also known as the Industrial Transformers site is located in Houston,
Texas. The area around the site is a mix of residential, commercial, and light industrial development.  The
residential population in the area is approximately 2,000, and a maximum daily traffic of 100,000 persons may
move within a one-mile radius due to recreational activities.  The site was used for electrical transformer
salvage and recycling between 1971 and 1978 and for chemical recycling and supply from 1979 through 1980.
An investigation during late 1971 by the Houston Water Pollution Control Division revealed that workers at
the site poured oil out of electrical transformers onto the ground during transformer dismantling.  In 1981,
strong odors originating from the site prompted further investigation, which found approximately 75 drums
scattered about the property.  Most of the drums,  labeled "trichloroethylene," were empty  and  had puncture
holes.  In 1986, the site was divided into operable  units to address soil and ground water contamination.  A
previous ROD addressed on-site  contaminated soil. This ROD addresses contaminated ground water in the
class IIB  aquifer directly below the site.  The primary contaminant of concern affecting the ground water is
TCE.

      The selected remedial action for this site  ncludes: ground water pump and treatment of approximately
12 million gallons using air stripping, with discharge to a POTW or reinjection into the water-bearing zone.
The estimated present worth cost for the remedial action  is $2,204,890.  O&M costs were not provided.

PERFORMANCE STANDARDS  OR GOALS:  Ground water  treatment will meet the MCL for TCE of 5
ug/1-

INSTITUTIONAL  CONTROLS:  Not applicable.
                                               B-116

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     SOUTH CAVALCADE, TX
                                    First Remedial Action -  Final
                                         September 26, 1988
ROD ABSTRACT
      The 66-acre South Calvacade site is located in northeast Houston, Texas.  The surrounding areas are
a mixture of residential, commercial, and industrial properties.  Stormwater runoff flows to two stormwater
drainage ditches, which flow into  Hunting Bayou, a  limited aquatic habitat as classified by Texas Water
Quality Standards. The site was used as a wood preserving and coal tar distillation facility from 1910 to 1962.
The wood preserving facility consisted  of an operations area, a drip  track,  and treated and untreated wood
storage  areas.  The  operations area included wood-treating cylinders,  chemical storage tanks, and a waste
water lagoon.   Creosote and metallic  salts were used in the operation.   Subsequently,  the site was sold,
divided into smaller tracts and resold to the current owners. The site is currently used by three commercial
trucking companies,  which have erected four buildings on the northern and southern parts  of the site.  In
1983, the Houston Metropolitan Transit Authority investigated the site for potential mass transit use and found
evidence of buried creosote.  Beginning in November 1985, EPA sampled all environmental media and found
two discrete areas of contamination at the site corresponding to the former locations  of the wood treating
operations  and coal  tar plant in  the southern portion of  the site,  and a pond  previously  existing  in  the
northern portion of the site.  PAHs, VOCs, metals, and components of creosote  were detected in the soil,
sediments,  and ground water.  The primary contaminants of concern affecting the ground water, soils, and
sediments are VOCs including benzene, toluene, xylenes, other organics including PAHs, and metals including
arsenic,  chromium, and lead.

      The selected remedial action for this site includes:  excavation  and  on-site washing of 19,500 yd3 of
soil, replacing the soil in the excavated  areas capping and treating wash water in the ground water treatment
system; in situ soil flushing of 10,500 yd of soil; ground water pump and treatment of 50,000,000 gallons using
physical/chemical separation, pressure filtration and carbon  adsorption with re-injection into the  aquifer or,
if necessary, discharge  to the on-site drainage ditch which flows into  Hunting Bayou; off-site incineration or
recycling of all non-aqueous phase liquids separated out from the ground water; and ground water monitoring.
Alternatively, in  situ biological treatment  of soil and ground  water will be considered if a  potentially
responsible party can demonstrate its equivalent or superior performance and implementability costs.  The
estimated present worth cost for this remedial action is $13,000,000.

PERFORMANCE STANDARDS OR GOALS:  Soil cleanup will attain a cumulative 10"5 cancer risk level.
Individual soil cleanup goals include CPAHs 700 mg/kg and no leaching potential (which may require removal
of total PAHs  above 150 mg/kg).  Ground water cleanup  will  attain a cumulative 10  cancer risk level.
Individual goals for  ground water  include:   CPAHs no detection, benzene 5 ug/1 (MCL), toluene  28 ug/1
(MCL), xylene  440 ug/1 (MCL), and arsenic, chromium, and lead 50 ug/1 (MCLs).

INSTITUTIONAL CONTROLS:  Deed restrictions will be implemented to control land use.
                                                B-117

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                           SOUTH VALLEY/EDMUNDS STREET, NM
                                      Second Remedial Action
                                           June 28, 1988
ROD ABSTRACT
      The South Valley/Edmunds Street site is a large area in the southern part of the City of Albuquerque,
New Mexico, surrounding the municipal water well known as San Jose 6. Within this large area are a number
of industrial properties  owned  and operated  by different groups and individuals.  This remedial  action
addresses the Edmunds Street Ground Water operable unit of the South Valley site.  The Edmunds Street
property is located in the southeastern corner of the site. The focus of this operable unit is the area around
the monitoring well SV-10, referred to as the drainage pit area,  on the Edmunds Street property. This area
is the low spot of the property and receives much of the property drainage. Analyses of this area have shown
significant levels of industrial solvents in the soil and a plume of contaminated ground water starting at the
drainage pit area and extending to the east. The ground water source will be treated as a sole-source aquifer
because there are no  alternate sources available to the City of Albuquerque. The contaminated ground water
currently poses a direct threat to Albuquerque's water supply by moving toward the city's well  fields. The
primary contaminants of concern affecting the ground water include VOCs such as PCE and TCE.

      The selected remedial action for this site includes:  ground water pump and treatment using  air stripping
(packed tower aeration), with reinjection of the treated water into the aquifer through  infiltration  galleries
and ground water and  air monitoring.  The present worth cost for this remedial action  is $874,000, with
present  worth O&M  costs  estimated at $280,200.

PERFORMANCE STANDARDS OR GOALS:  The contaminated ground  water will be treated to a PCE
level of 20 ug/1 as required by the New Mexico Water Quality  Control Commission  regulations, and to the
MCL for TCE of 5  ug/1 as required by the Safe Drinking Water Act.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-118

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                    SOUTH VALLEY/SJ-6, NM
                                       Third Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The South Valley/SJ-6 site is located on the southern margin of Albuquerque, New Mexico, just north
of South Valley.  The total site encompasses the SJ-6 municipal well and six industrial facilities and  their
surrounding properties within an  approximately one-mile radius.   Land  use is  primarily industrial  and
agricultural with residential areas  located immediately north  of  the site.  Industrial development began in
the South Valley area just prior to the  1940s.  Metal parts were manufactured in  the area starting around
1948. By the 1960s, organic chemicals were being handled and packaged on the site.  Currently, petroleum
fuels and various chlorinated organics are stored, handled, and used within the South Valley areas.  Ground
water contamination was first suspected in 1978 when foul tastes and odors were noted in ground water from
a private well on the Edmunds property in South Valley.  Subsequent sampling revealed the presence of
several VOCs in three municipal wells including SJ-6.  One of the wells was resampled in  1988 and found
to be free of contaminants, another well was taken out of service because of mechanical problems, and SJ-6
was shut down in 1980 due to the continual detection  of low levels of solvents.  This  ROD addresses only
the source and extent of ground water contamination  in the vicinity of SJ-6. Principle threats at the site (i.e.,
the source and emanating plumes of contamination  from surrounding areas)  are being addressed through
remedial actions initiated  by EPA in separate RODs.  The primary contaminants of concern  affecting the
ground water are VOCS including 1,1-DCE, PCE, and TCE.
                                                                                   o
      The selected remedial action for  this site includes: removal and disposal of 100 yd  of contaminated
sediments at  the base of the SJ-6 borehole; sealing abandoned wells; ground water monitoring; and access
restrictions.  The estimated present worth cost for this remedial action is $4,000,000 with estimated annual
O&M of $300,000.

PERFORMANCE STANDARDS OR GOALS:  All risks to human health will be eliminated by the removal
and disposal of sediments at the base of the SJ-6 borehole which appear to be the  source of contamination.
Remediation on adjacent sites as well as source control at this site will reduce plume concentrations to below
state health criteria within five years. Federal health criteria  are already being met.

INSTITUTIONAL CONTROLS: Restrictions will be implemented to ensure that wells are constructed using
techniques that prevent  cross-contamination  of  zones  and  are deep  enough to prevent  exposure  to
contaminants.
                                                B-119

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   SOUTH VALLEY/FL-83, NM
                                      Fourth Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The Former Air Force Plant 83/General Electric Operable Unit (PL-83) is  a portion of the South
Valley site in Albuquerque,  New Mexico.   The  South Valley site is an  area  surrounding the City of
Albuquerque Municipal Water Well known as San Jose No. 6,  The General Electric (GE) property is located
in the western portion of the site.  The South Valley site is situated  in an industrial  area, but there are
residences immediately north  of the GE property, which has been the site of manufacturing operations since
1948 when the Eidal Manufacturing Company had  a welding operation  on-site.  In 1951 the Atomic Energy
Commission, through American Car Foundry, took over the property and conducted machining of metal parts,
plating, welding,  and other activities.  This continued until 1967  when the Air Force took over the property
and converted the plant into an aircraft engine manufacturing plant operated by General Electric.  The plant
was sold to General Electric in 1983, and currently produces aircraft engine parts.  The contaminants which
caused the listing of the South Valley site on the NPL consisted mainly  of industrial  solvents.  Investigations
into the GE property were conducted in 1984, 1985, 1987, and 1988 by the Air Force under a Memorandum
of Understanding with EPA.   The GE property is heavily built up, with the majority of the site paved or
covered with buildings.  As a military contracting facility, access to the  plant is tightly controlled and  there
is no  regular access other than by employees.  Three areas of contamination have been identified at the site:
four hazardous waste  storage areas which were used for chemical storage, the north parking lot (a former
dirt parking lot which was sprayed with oil as a dust control measure), and the DWB-2 area which contains
methylene chloride and freon contamination.  The volume of contaminated soils is estimated to be 36,000 yd  .
In addition to soil contamination, ground water contamination occurs  at  depths  of up to 160 feet.  The
primary contaminants  of concern affecting the ground  water and soil are VOCs, including PCE, and metals.

      The selected remedial action for this site includes:  installation of soil vapor extraction wells; extraction
of soil vapor under vacuum;  decontamination of effluent air through a carbon adsorption system; further
sampling and definition of soil contamination; installation of ground water extraction wells in both the shallow
aquifer  and the  deeper zone; treatment of extracted ground water with air stripping  followed  by carbon
adsorption and reinjection of treated water into the aquifers (chemical or physical treatment of ground water
will occur where metal concentrations exceed background or ARARs); and further definition of ground water
contamination through installation and sampling of additional monitoring wells.  The estimated present worth
cost  for soil remediation is $1,820,000.  No figures are given in the ROD for the  ground water remedial
action.

PERFORMANCE STANDARDS OR GOALS: Soils treatment will continue until the vapor extraction system
ceases to  produce volatile contaminants.  Water extraction will  continue until the  levels of contaminants in
the water fall below State and Federal regulatory standards. Individual contaminant goals were not specified.

INSTITUTIONAL CONTROLS:   Not applicable.
                                                B-120

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                            STEWCO, TX
                                     First Remedial Action - Final
                                          September 16,  1988
ROD ABSTRACT
       The Stewco site, previously a tanker truck terminal and truck washing facility, is located in northeastern
Texas, in Eastern Harrison County, south of the city limits of Waskom. The site consists of two nonadjacent
locations approximately one mile apart, referred to as Location 1 and Location 2.  Location 1 is a one-half
acre plot  that includes a maintenance shop with fueling facilities,  a  truck-tank washing facility,  and two
backfilled  and capped  evaporation ponds (ponds  1 and 2) that received  wastewater  from the  tank washing
operation.  Approximately 50 homes are located within one-half mile of Location 1; four of these are within
500 feet of the north, west, and south  site boundaries.   In addition, shallow wells are located approximately
one mile to the  north.  Location 2 consists of a  third pond  which received excess wastewater conveyed by
truck  from the evaporation ponds at Location 1.  Approximately 30 homes are within a one-half mile radius
of Location 2.  Land  use within a one mile  radius of the two  locations  includes residential, recreation,
industrial, and commercial.  The underlying Wilcox aquifer serves  the city of Waskom  as  well as numerous
domestic users within a three mile radius of the site.  From 1972 through  1979, R A. Corbett Transport, Inc.,
owned, operated, and maintained a fleet of transport trucks  engaged in contract hauling for the oil and gas
industry and various businesses.  Stewco purchased the site in 1979 and continued operations until declaring
bankruptcy in 1983.  Materials hauled included  glue, resin, gasoline, diesel, jet fuel, and  creosote.   The
wastewater generated from washing the outside of trucks and the tank residue resulting from steam cleaning
the inside of the tankers were directed to pond 1, with overflow entering pond 2 and  the surplus transported
to the third pond at Location 2.  All ponds were  unlined. Reports from  the Texas Water Commission files
indicate numerolis instances of noncompliance with permit requirements.  After  abandonment in 1983, ponds
1 and  2 began to  overflow their dikes, creating a serious threat of dike  collapse and significant hazardous
substances release.  Consequently, EPA conducted a removal action at Location 1 from March 31 to April
14, 1984.  The action consisted  of removing  the  source of contamination:  400,000 gallons of liquid wastes
were pumped, treated, and discharged; and 5,500 yd  of sludges from the bottom and  sides of the disposal
ponds  were stabilized and disposed of off-site.  The pond disposal area was then backfilled and capped. No
removal or remedial actions were taken at Location  2 since  the level of  contamination was much less than
that of Location 1 and the pond was  not  filled near capacity.   The contaminants of concern prior  to the
removal action were VOCs, PAHs, and phthalates.

       EPA determined that,  based on  the effectiveness  of  the previous removal  action,  the residual
contamination remaining in the soil, pond sediments, and ground water poses no threat to public health and
that no long-term monitoring is necessary.  Therefore, no further action will be  taken at this site.  However,
ground water contamination has been identified that is not attributed to  the site. Follow-up actions by the
State and  EPA will attempt to  determine the source of this  contamination.  If within 2 years of the signing
of this ROD,  wells  on-site at Stewco  are  determined  to be of no use to  the  off-site  source  investigation,
closure will be initiated.  The cost of plugging the 16 wells is estimated not to  exceed $5,000.

PERFORMANCE  STANDARDS OR GOALS:  Chemical-specific goals met by this no action  remedy were
not specified.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-121

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                            UNITED NUCLEAR CORPORATION, NM
                                       First Remedial Action
                                        September 30, 1988
ROD ABSTRACT
      The United Nuclear Corporation (UNC) site is located approximately 17 miles northeast of Gallup,
in McKinley County, New Mexico. The site operated as a State-licensed uranium mill facility from June 1977
to May 1982.  It includes an ore processing mill (about 25 acres) and an unlined tailings pond area (about
100 acres). The surrounding area is sparsely populated, with the nearest residence located 1.5 miles from the
site.  In July 1979, approximately 23 million gallons of tailings and pond water were released to a nearby river
as a result of a dam breach in the tailings  pond area.  The site damage was repaired; however, attention was
focused on ground water contamination resulting from tailings seepage.  Consequently,  UNC implemented
a ground water pumping system that withdrew ground water from the aquifers underlying the site and sent
it to an on-site borrow pit for evaporation.  UNC also conducted tailings neutralization from late 1979 to early
1982.  Nevertheless, the off-site migration of radionuclides and  chemical constituents from uranium  milling
byproduct materials into the ground water, as well as to surface water  and air,  are still  principal threats at
the  site.  This remedial action will address on-site ground water contamination.   Source  control and on-site
surface reclamation will be implemented  under the direction of the Nuclear Regulatory Commission and
integrated with this ground water operable unit. The primary contaminants of concern affecting the ground
water are metals including arsenic and radioactive substances including  radium-226/228 and gross alpha.

      The selected remedial action for this site includes:  implementation of  a ground water monitoring
program  to detect any increases in the areal extent or concentration of ground water contamination outside
the  tailings disposal area; ground water pump  and treatment using existing and/or new extraction wells to
control and remove tailings seepage and remediate contaminated ground water, with discharge to an enhanced
mister/pond evaporation system; and implementation  of a performance monitoring and evaluation  program.
The estimated present worth cost for this remedial action is $17,000,000 over a 10-year period, with estimated
annual O&M of $1,000,000.

PERFORMANCE STANDARDS OR GOALS:  Contaminant concentrations in ground water will attain MCLs
or New Mexico  Water Quality Act standards  (or  background  levels where these are higher). Individual
cleanup  goals include  arsenic 50  ug/1 (MCL), cadmium  10  ug/1  (MCL), cobalt  50 ug/1  (NMWQA),
radium-226/228 5 pCi/L (MCL), selenium 10 ug/1 (MCL), and gross alpha 15 pCi/L (MCL).

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-122

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                      Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    ARKANSAS CITY DUMP, KS
                                        First Remedial Action
                                          September 29, 1988
ROD ABSTRACT
      The 200-acre Arkansas City Dump site is located in the southwest section of Arkansas City,  Cowley
County, Kansas, and is bounded on the west and south by a levee that separates it from the Arkansas River.
The site falls within the 100-year floodplain and includes a north waste area and a south waste area, both
located  in the central portion.   Land use adjacent to the site is a mixture of crop land and rangeland and
commercial and residential areas.  Urban areas  exist to the north and east of the site with residential areas
bordering on the north and mixed residential and commercial areas on the east. Approximately 60 residences
are adjacent to the eastern boundary, and several businesses that employ about 100 to 150 people are located
on-site.   Ground water flows predominantly to either the southwest or  southeast toward the Arkansas River
due to a ground water  divide that exists near the center of the site.  Upgradient ground water is used for
drinking purposes by Arkansas City as well as private  residences.  Downgradient, east and southeast of the
site, private wells are used to provide  water primarily  for lawn and garden watering.  The site was  used as
an  oil refinery between 1916 and the mid-1920s.  Residual acid sludge from the distillation process  was
disposed of in pits or on the ground predominantly  in the north waste  area.  Subsequently, 160 acres were
used as  a municipal landfill, referred to as the Arkansas City Landfill. For over 50 years,  alkaline sludge from
Arkansas City's water treatment plant,  as well as  municipal refuse and solid wastes were  disposed  into
lime-sludge ponds located in the south waste  area.  Investigations conducted since 1980 by  the  Kansas
Department of  Health  and Environment have  determined  that all media are contaminated with  various
organics and inorganics, primarily from refining wastes. This contamination is a result of 1,300,000 ft  of  acid
sludge and between 500,000 to 1,000,000 gallons  of residual oil product, which has mixed with the subsurface
soil  predominantly  between the  north  and  south waste  areas.   The principal contributor  of  organic
contaminants to the ground water, particularly polynuclear aromatic hydrocarbons (PAHs), appears to be the
soil  contaminated  sediments in the subsurface.  However, contaminants are not migrating off-site.  This
Record  of Decision (ROD) addresses remediation of acid sludge in the north waste area; a subsequent ROD
will address the oil-contaminated sediments and ground water contamination.  The primary contaminants of
concern in the acid sludge are  organics, including PAHs and sulfuric acid.

      The selected  remedial action for the north waste area operable  unit includes:  in  situ neutralization
of the acid sludge followed by the installation of a soil cover; completion of a supplemental feasibility study
addressing remedial alternatives for the subsequent  operable  unit; institutional  controls including deed
restrictions; and ground water monitoring.

PERFORMANCE STANDARDS OR GOALS:  Neutralization of acid sludge will attain a pH less than 2.0
and eliminate  the potential for sulfur dioxide emissions.

INSTITUTIONAL CONTROLS: Deed restrictions and other institutional controls will be implemented to
prohibit  soil  excavation  and construction of buildings on  any  part of  the  site still containing hazardous
materials, and  to ensure that drinking water supply wells  are  not drilled  into contaminated parts  of  the
aquifer.
                                                B-123

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                      BIG RIVER SAND, KS
                                   First Remedial Action - Final
                                          June 28, 1988
ROD ABSTRACT
      The Big River Sand (BRS) site is located one-half mile west of the Arkansas River and adjacent to
the Wichita Valley Center Floodway, in Sedwick County, Kansas.  The site consists of approximately 123 acres,
half of which has been extensively mined for sand and gravel.  Sand and gravel mining is still active on the
property.  During the early 1970s, approximately 2,000 drums of paint-related waste were  disposed of on the
eastern portion of the site, adjacent to a five-acre sand quarry lake.  In 1978, 80 acres of the site containing
the drum  storage area  and quarry lake were sold to BRS.  In 1982, as a condition of the sales agreement,
the drums were  moved to an unsold portion  of the  site.  Nearly 200 drums were  transferred  before the
Kansas  Department  of Health  and Environment  (KDHE) halted the action because  the  area was not
permitted  to store or dispose of the waste. KDHE  conducted the initial site inspection in August 1982 and
identified  damaged, corroded,  and leaking drums.   Paint  sludges were  determined to be EP-toxic for
chromium, and waste solvents and paint sludges from several  drums contained metals and VOCs. Waste
solvents from the barrels were determined to be  hazardous due to their ignitability. A PRP was ordered by
KDHE in September 1982 to conduct a removal and site cleanup.  These occurred between 1982 and  1984.
Sampling by KDHE between 1982 and 1985 detected arsenic, lead, and selenium in drinking water wells, and
VOCs, including toluene, in on-site soils and monitoring wells.

      It has been  determined that the site does not pose a significant threat to public health, welfare and
the environment. Therefore, no further action  has been selected as the preferred alternative. The estimated
future cost, if sampling is conducted in year five, is  $5,800.

PERFORMANCE STANDARDS OR GOALS:  Metals and VOCs in the soil and ground water are not outside
the range  of metals and VOCs found naturally occurring in soil and ground water. Additionally, no MCLs
are being  exceeded in on-site or off-site drinking water wells.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-124

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                               CHEROKEE COUNTY/GALENA, KS
                                       First Remedial Action
                                         December 21, 1987
ROD ABSTRACT
      The Cherokee County site, the Kansas portion of the  Tri-State Mining District,  is located in the
extreme southeastern corner of Kansas.  The Galena subsite, one of six subsites identified within the Cheroke*.
County  site, encompasses 18  square miles.  The Galena subsite is  characterized by surface mining waste
features that impact  the  quality of the shallow ground water aquifer.  This aquifer  is a primary source of
drinking water for approximately  1,050 people.  Remains from past mining activity  at  the subsite include:
large areas covered by mine and  mill wastes, water-filled subsidence craters, and open mine shafts.  EPA
investigations of the Galena subsite conducted in 1986 and 1987 demonstrated that the shallow ground water
aquifer and surface water are contaminated with elevated concentrations of metals.  Due to the concern for
the health of persons drinking this water, EPA Region VII conducted a removal action and installed water
treatment  units on these  wells.  This removal action was considered a temporary protective measure.  The
primary contaminants of  concern observed in  the private wells include:  cadmium, lead, selenium, and zinc.

      The selected remedial  action for this site provides for collection of water from  the aquifer through
existing  wells owned by the  City  of Galena with subsequent distribution of that water through a pipeline
network to 418 houses, businesses, and farms outside of the Galena municipal water system but within the
subsite.  Additional capacity for the expanded  system will be rehabilitated.  If rehabilition becomes infeasible
due to unforeseen on-site technicalities, a new deep aquifer well may be drilled to provide additional water.
The remedy includes acquiring  the  construction and equipment necessary to setup  a water supply to this
area.  The estimated present worth  cost for this remedy is $5,300,000 with annual O&M of $100,000.

PERFORMANCE STANDARDS OR GOALS: Extracted ground water will be chlorinated prior to discharge
and will meet the MCLs  for cadmium 10 ug/1, lead  50 ug/1, selenium 10  ug/1, and zinc 5,000 ug/1.

INSTITUTIONAL CONTROLS:   Existing institutional  controls on municipal  water  supply systems are
considered adequate.
                                               B-125

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                              JOHN DEERE DUBUQUE WORKS, IA
                                    First Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The John Deere Dubuque Works site is located approximately 2.5 miles north of the City of Dubuque,
Iowa. The site is owned by Deere and Company, which has operated a manufacturing plant at the site since
1946. The plant property includes an area of 1,447 acres located in the flood plain at the confluence of the
Little Maquoketa River and the Mississippi River.  The  waste management history of the plant is complex,
but the primary area of concern  is an unlined landfill originally placed in a natural depression caused by
the Little  Maquoketa River.   Prior to 1968,  wastes were placed in the  low areas of the landfill and
combustible materials were burned.   Wastes  included  caustics  (sodium or  potassium hydroxide),  acids
(hydrochloric or sulfuric), petroleum distillates (solvents, grinding oils, and so forth), heavy metals (chromium,
lead,  zinc), cyanide, and paint sludges.  Another  area  of concern at  the facility is the site of  a 1980
200,000-gallon diesel fuel spill.  A diesel fuel recovery system involving an oil/water separator for non-aqueous
phase liquids (NAPLs) was implemented that same year.  Investigations conducted by John  Deere indicated
that human health hazards at the landfill could be  considered minimal with the primary hazard being the
possibility of dissolved organic chemicals impacting off-site domestic wells located east of the plant  along the
Mississippi River. Maintaining a minimum pumping rate of 1.2 mgd in the plant production wells will create
sufficient drawdown to prevent migration of contaminated ground water to the off-site wells.   The primary
contaminants of concern affecting the ground water  are VOCs including benzene, PCE, TCE, and toluene.

      The selected remedial action for this site includes:  development of an alternate potable water supply
for the  plant; extraction and off-site discharge of water from the contaminated alluvial aquifer using the
existing production wells to maintain drawdown around the plant and landfill areas; continuation of extraction
and treatment of NAPLs from production well No. 3 with off-site discharge of treated ground water and off-
site disposal of collected NAPLs; imposition  of deed restrictions to prevent inappropriate use of the plant
property in the future; and development of a contingency plan to ensure that contaminants do not migrate
off-site in the event of a plant shutdown (which would result in the loss of drawdown from production wells).
The estimated present worth cost for this remedial action is $5,151,800 with annual  O&M costs of $276,600.

PERFORMANCE STANDARDS OR GOALS:  Recovery operations will continue until ground water quality
meets Federal primary drinking water standards  (MCLs) and EPA Health Advisories, and until the maximum
recoverable amount of NAPL is withdrawn.  Individual contaminant goals were not specified.

INSTITUTIONAL CONTROLS:  Deed  restrictions will be imposed to ensure that future use of the current
plant property will be limited to  industrial activities only, and that water  wells tapping the alluvial aquifer
beneath the property will not be allowed.
                                                B-126

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                            FULBRIGHT/SAC RIVER LANDFILLS, MO
                                    First Remedial Action - Final
                                         September 30, 1988
ROD ABSTRACT
      The Fulbright and Sac River Landfills are located just north of the City of Springfield, Missouri, in
a semirural area.   The site is in the flood plain of the Little Sac  River, and  is owned by the City of
Springfield, along with much of the surrounding land.  Adjacent land  use includes a police shooting range,
an animal shelter,  and an inactive wastewater treatment plant.  The landfills were operated by the city for
the disposal of municipal and industrial solid wastes.  The Fulbright Landfill covered 98 acres and operated
from 1962 through 1968.  The Sac River Landfill, formerly known as the Murray Landfill, covered 114 acres
and was in operation from 1968 through 1974.  Generally, wastes  (drummed  or bulk) were disposed of in
trenches and covered with soil.  The City of Springfield and Litton Industries, Inc.,  agreed to conduct the RI
and the FS under the oversight of EPA.  Several leachate seeps have been  noted, especially during wet
weather.  In addition to the landfill areas, another source of contamination was  identified where a few dozen
drums and waste residues were disposed of  in a sinkhole on the bluff above the Fulbright Landfill.  Based
on data from the RI, environmental contaminant concentrations in soil,  ground water, leachate, surface water,
and sediments do not exceed  applicable  or relevant  and appropriate  requirement standards.  The site,
however, could endanger human health or the environment in the future through exposure of the industrial
wastes through erosion of the  landfill cover,  installation of drinking water wells at or  near the landfills, or
from direct contact with leachate at the seeps.  While  a reference is made to  disposal of cyanide and acid
wastes, the primary contaminants of concern affecting the media investigated are not listed in the ROD.

      The selected remedial action for  this  site includes:  removal of the drum and drum remnants found
in the sinkhole  and associated trench east  of the Fulbright Landfill; sampling  the removed contents  to
determine hazardous characteristics; proper  off-site treatment or disposal of removed  contents; observation
of the leachate seeps during maintenance (no action), ground and surface water  monitoring for a 30-year
maintenance period; and imposition of deed restrictions and ground water use prohibitions.  The estimated
present  worth cost for this remedial  action  is $270,400 if wastes are disposed of as hazardous waste  or
$246,600 if disposed of as solid waste.

PERFORMANCE STANDARDS OR GOALS: Individual contaminant goals were  not specified.

INSTITUTIONAL  CONTROLS:   Deed restrictions  will  be imposed  on the  city property  containing  the
landfills.
                                               B-127

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                    HASTINGS GROUND WATER/COLORADO AVENUE, NE
                                        First Remedial Action
                                         September 28, 1988
ROD ABSTRACT
      The Colorado Avenue subsite of the Hastings Ground Water Contamination site is located in the City
of Hastings, Adams County, Nebraska.  The Colorado Avenue subsite is a part of the Central Industrial Area
which  contains  commercial  and  industrial properties  situated  along  the Burlington-Northern railroad
right-of-way.  Residential properties are located immediately south and east of the site.  Hastings industries
used TCE  at the site during the early  to mid-1960s. From 1967  to May 1982 the site  was used by Dravo
Corporation for manufacturing of  heating and air conditioning equipment.  Metals  were cleaned prior to
finishing with a vapor-degreasing process, and waste solvents were discharged directly into the sanitary sewer
and the storm sewer.  The site has since been  acquired by Marshalltown Instruments Company, that claims
to have no involvement  with  disposal of the  chemical contaminants.   Ground water contamination was
discovered  when an out-of-service drinking water well was put back in service in 1983, resulting in complaints
about the water quality.  Subsequently, the  Nebraska Department  of Health and the Nebraska  Department
of Environmental Control began investigating widespread ground water contamination in the Hastings area.
Active Hastings municipal water wells  are located within one block, 3,000 feet, and 4,500 feet of the site,
all three accessing a sole  source aquifer. The highest levels  of contamination of soil and  soil-gas occur along
the sanitary and storm sewers  at the site with localized areas which correspond to joints in the sewers.  The
volume  of contaminated soil is estimated to be 42,700 yd  and is the focus  of this ROD.  High levels of the
contaminants are also found in the ground water beneath the site.  The primary  contaminants of concern
affecting soil  and ground water are VOCs, including TCE and PCE.

      The selected remedial  action  for  this site includes:  in  situ soil  vapor extraction, utilizing vacuum
extraction  technologies; treatment  of extracted vapor with an  activated carbon system, if necessary; and
implementation of an O&M program which  includes soil, air,  and  ground water  monitoring.  Results of the
ground water monitoring will be used to  develop a technical approach for plume management and evaluate
the need for ground  water  treatment  in a subsequent ROD.  The estimated present  worth cost for this
remedial action is $3,603,000, which includes a projection of annual O&M costs for the five year operating
period.   Long term O&M costs will depend on the success  of the vapor extraction during the operating
period.

PERFORMANCE STANDARDS OR GOALS:  The initial source control effort is designed to control
contaminant  migration  to the aquifer,  therefore,  no  cleanup levels  have  been  established.   Cleanup
effectiveness will  be evaluated  based  on volumes of contaminants recovered from the soil.

INSTITUTIONAL CONTROLS: Not applicable.
                                               B-128

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                         HASTINGS GROUND WATER/FAR-MAR-CO, NE
                                        First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The FAR-MAR-CO subsite of the Hastings Ground Water site is located east of the City of Hastings,
Adams County, Nebraska.  The subsite is a part of an industrial enterprise zone which contains industrial
properties situated along the Burlington-Northern railroad right-of-way.   Residential properties  are located
immediately northwest of the site and agricultural lands are located east of the site.  Historical and current
use of the area has been  for grain storage and railcar loading.  The site is  currently owned by Farmland
Industries, Inc., that acquired the property through a merger with FAR-MAR-CO, Inc., in 1967.  The current
and previous owners  used various chemicals  on-site for fumigation of stored grain.  Contamination  was
discovered when  complaints  about water quality were received by the Nebraska  Department  of Health
(NDOH).   Subsequently,  the  NDOH  and the Nebraska Department  of Environmental Control  began
investigating widespread ground water contamination in the Hastings area.  Wells that are part of  CMS, Inc.,
public supply system are located east and downgradient of the subsite. Contaminated soil at the  subsite are
believed to be the result of accidental spills and may be the direct result of a 1959 grain dust explosion which
damaged a fumigation tank system, releasing 997 gallons of fumigant.  The highest levels  of contamination
of soil and soil-gas occur  in relatively small zones near the original grain elevator and adjacent to a large
liquid fumigant bulk storage tank.  The volume of contaminated soil is estimated to be 33,800 yd  and is the
focus  of this ROD.   High levels of the contaminants are also found in the ground water  beneath the site.
The primary contaminants of concern affecting soil  and ground water are carbon tetrachloride and ethylene
dibromide (EDB).

      The selected remedial action for this site includes:  in  situ soil vapor extraction,  utilizing vacuum
extraction technologies; treatment  of extracted vapor with an activated  carbon system, if  necessary;  access
restrictions; and implementation of an O&M program which includes soil, air, and ground water monitoring.
Results of the ground water monitoring will be used to develop a technical approach for plume management
and evaluate the need for  ground water treatment in a subsequent ROD. The estimated present  worth cost
for this remedial action is $2,526,000, which includes a projection of annual O&M costs  for the five year
operating period.  Long-term O&M costs  will depend on the success  of  the vapor  extraction  during the
operating period.

PERFORMANCE  STANDARDS  OR GOALS:  This  initial source control  effort  is designed  to control
contaminant migration to the aquifer, therefore no cleanup levels are established.  Cleanup effectiveness will
be evaluated based on volumes of contaminants recovered from the soil.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-129

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                        MIDWEST MANUFACTURING/NORTH FARM, IA
                                        First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
       The North Farm operable unit is one of two subsites of the Midwest Manufacturing site and is located
hi a rural  area  approximately two miles north and  one-half mile east of Kellogg, Jasper County, Iowa.
Approximately 600 people live hi Kellogg.  Land use  near the site is mainly agricultural, with pasture land
on and around the site. The closest residence to the North Farm subsite is approximately one mile from the
site. The subsite consists of an unlined disposal cell containing approximately 200 yd of soil contaminated
with electroplating wastes.   The disposal cell is located on the lower slope of a rolling  hill adjacent to the
valley of Bear Creek, which is an intermittent stream located 500 feet east of the site.  Bear Creek lies 50
feet lower than the site. Records indicate that electroplating activities took place at this site prior  to 1979
and ceased operations  in June 1981.  Activities involved the use of various heavy metals,  including cadmium,
nickel, and zinc,  as well as cyanide.  In  1977, a wastewater treatment plant was installed at the facility to treat
the plant effluent before it was discharged into the North Skunk River.  Solids generated at the treatment
plant were temporarily stored in a tank on-site and periodically transferred to the disposal cell.  The disposal
cell was unlined and had no  soil cap, leachate  collection system, or run-on and run-off controls. Soil sampling
was conducted on-site and  downslope  in 1982 and 1983 to evaluate  the potential for off-site contaminant
migration due to previous waste disposal practices.  Analysis of the samples revealed that soil contamination
had occurred via surface run-off.  The  primary contaminants of concern affecting the soil are cadmium and
cyanide.

       The selected remedial action for this operable unit includes:  excavation of cadmium-contaminated soil
within and around the disposal cell with either on-site or off-site soil treatment including stabilization, and
off-site disposal  of the treated soil at a permitted RCRA Subtitle C disposal facility;  and backfilling and
grading of the excavated area with clean soil to support a vegetative cover. The estimated total present worth
cost for this remediation is $140,000 - $170,000.  The remedial action for the Midwest Manufacturing operable
unit of this  site will be addressed in a  subsequent ROD.

PERFORMANCE  STANDARDS  OR  GOALS:    Contaminated  soil will  be  excavated to  less than the
health-based action level of  13 mg/kg for cadmium. Treated soil will meet the treatment standards specified
in the Land Disposal Restrictions for F006 non-wastewaters and will be measured as a leachate contaminant
concentration using the TCLP.  The treatment standards are cadmium 0.066  mg/L, total chromium 5.2 mg/L,
lead 0.51 mg/L, nickel 0.32  mg/L, and silver 0.072 mg/L.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-130

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                            MINKER/STOUT/ROMAINE CREEK, MO
                                      Second Remedial Action
                                         September 29, 1988
ROD ABSTRACT
      The Minker/Stout/Romaine Creek (M/S/RC) site is located in the city of Imperial, Jefferson County,
Missouri, 25 miles southwest of St. Louis.  The site is  an unincorporated, wooded residential area and is
comprised of four noncontiguous areas:   Minker, Stout,  Cashel, and  Sullins.  It is  within a distance  of
approximately 0.8 miles and includes the upper 6000 feet of Romaine  Creek.  Contamination at  the site
resulted from the use of dioxin-contaminated soil as fill material, and has spread as a result of erosion from
these areas.  Contaminated soil in all areas except the Stout area and Romaine Creek has been excavated
and currently is stored in interim on-site storage.  The total volume of contaminated soil at this site including
the amount in temporary storage is estimated to be 12,000 cubic yards.  The primary contaminant of concern
affecting the soil at this site is 2,3,7,8-TCDD (dioxin).

      The selected remedial action for this site includes:  excavation of soil exceeding  20 ppb dioxin and
off-site thermal treatment  and incinerator ash disposal at the Times Beach site, placing  of clean soil cover
and  revegetation  over  all areas with residual dioxin levels  between 1  and 20 ppb,  and off-site  thermal
treatment  and incinerator ash disposal at the Times Beach site of contaminated soil held in interim  storage.
The  estimated total capital cost for this remedial action is $48,800,000, which includes all costs from the Times
Beach site.

PERFORMANCE STANDARDS OR GOALS:  Soil cleanup levels will  attain  a 1 ppb  dioxin level at the
ground surface  and a 5 to 10  ppb dioxin level at a depth of one foot or greater.  Thermal  treatment will
attain (99.9999 percent) destruction and removal efficiency of dioxin from soil.

INSTITUTIONAL CONTROLS: Institutional controls will be established to control future land use and  to
prevent  future residential development.
                                               B-131

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  SHENANDOAH STABLES, MO
                                        First Remedial Action
                                            July 28, 1988
ROD ABSTRACT
      The Shenandoah Stables (SS) site is located in a rural area near  Moscow Mills, Lincoln County,
Missouri, approximately 35 miles northwest of St. Louis, Missouri.  The property includes an enclosed arena
and horse stables.  There are about 8 residences located within a 0.5 mile radius of the site, as well as a
livestock operation and other small businesses on approximately 5- to 10-acre parcels around the facility. The
site lies in the upper flood plain of Crooked Creek.  In May 1971, the area inside the arena was sprayed with
dioxm-contaminated waste oil  for dust control  purposes.  There  are  reports that 1,500 gallons of waste
material were applied at this time. Following this spraying, a number of adverse effects were noted: horses
and other animals became ill or died, and the six-year-old daughter of one of the owners was hospitalized
for a variety of symptoms  assumed to be related to exposure to contaminated  soil.  Between August 1971
and March 1972,  approximately 24 to 26 inches of the  contaminated material was removed  and disposed of
either off-site or on-site in two  removal episodes. Investigations were conducted  by EPA in May 1982, which
indicated continued exterior and interior contamination of the facility by dioxin at levels greater than 1,750
ug/kg.  Since the spraying, the site has been flooded a number of times, with water  levels inside the arena
as high as four feet above the arena floor. Investigations have shown contamination  of approximately 8,600
yd  of ulterior and exterior site areas.  The primary contaminant of concern affecting the soil and structures
at the site is dioxin.

      The selected remedial action for this site  includes:  excavation of all dioxin-contaminated surface soil
exceeding 1  ug/kg with continued excavation until a residual concentration of 5 to 10 ug/kg at the 2 to 4-foot
depth is reached in the arena  and slough; or, excavation until bedrock is  encountered,  with backfilling of
excavated  area, placement of the excavated soil in lined polypropylene bags, and storage  of the bags in
RCRA-equivalent  enclosed steel  storage  structures  on-site; and  decontamination  of  on-site structures.
Approximately 3,300 yd of soil are expected to be excavated and stored. The estimated present worth cost
for this remedial  action is $3,936,500.

PERFORMANCE STANDARDS OR GOALS:  Excavation of surface soil exceeding 1 ug/kg dioxin, and 5
to 10 ug/kg at a 2-foot depth in the  arena or 1-foot depth in other areas, to a maximum 4-foot depth or to
bedrock based on health-based action levels provided by ATSDR.

INSTITUTIONAL CONTROLS:  The arena and stables are to be closed and access  to the  property will be
restricted.
                                                B-132

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                      SYNTEX VERONA, MO
                                    First Remedial Action - Final
                                            May 5, 1988
ROD ABSTRACT
      The Syntex Verona  (SV) site,  formerly operated as Hoffman-Taff Inc., was purchased in 1969 by
Syntex Agribusiness.  The site is located 30 miles southwest of Springfield in extreme southwestern Missouri.
Approximately 500 people live in Verona, Missouri, which borders  on the site.  The site area encompasses
approximately 180 acres along the east bank of the Spring River. The majority of the active portion of the
facility is located within the Spring River 100-year flood plain.  SV was used to manufacture hexachlorophene
from  1970 to 1971 and produced the  byproduct 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), referred to as
dioxin.  From 1971 to 1988, EPA and Syntex Verona conducted numerous site investigations.  The findings
showed  contamination both on- and off-site which may be related to the former activities at the site.  The
major areas identified as being contaminated are the Slough Area, Lagoon Area, Spill Area/Irrigation Area,
Burn Area, and Trench Area.  Dioxin contamination ranged from 1 ug/kg to 1,380 ug/kg, with the maximum
concentrations occurring  in the  Lagoon  Area.   In addition  to dioxin contamination, other organics and
inorganic compounds were identified.  The concentrations of these compounds were below the level of concern
for human health. The primary contaminant of concern affecting the soil is dioxin.

      The selected  remedial action for  this site includes:   excavation  and off-site thermal treatment of
dioxin-contaminated  soil  exceeding  20 ug/kg  and  off-site disposal  of  the  ash residue, dismantling and
decontamination of equipment with a  series of solutions and aqueous rinses, installation of a clay cap with
a vegetation cover over the Trench Area; and maintenance of vegetation cover over surface soil containing
levels of dioxin from 1 ug/kg to 20 ug/kg.  The estimated present worth cost for this remedial action is
$5,617,000.

PERFORMANCE STANDARDS  OR GOALS:  A site-specific action level of 20 ug/1 has been established
as an appropriate cleanup level for dioxin-contaminated soil.

INSTITUTIONAL CONTROLS:  Not  applicable.
                                               B-133

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                        TIMES BEACH, MO
                                       Second Remedial Action
                                         September 29, 1988
ROD ABSTRACT
      The Times Beach site is a 0.8 square-mile area located in the formerly incorporated city of Times
Beach, St. Louis  County, Missouri, approximately 20  miles southwest of the city of St. Louis.  The site is
bordered on the north and  east by the Meramec River and areas of St. Louis County, on the south by areas
of Jefferson County, and on the west by the City of Eureka. Land use of the surrounding areas is primarily
residental and agricultural.   The majority of the site falls within the five-year flood plain and  the entire site
falls within the 25-year flood plain of the Meramec River.  The soil contamination at the site is a result of
spraying  roads for dust control in the  1970s with oil that was contaminated with dioxin.  Investigations
indicate that the contamination is limited to the roads, road shoulders, and drainage ditches along the roads
and is generally limited to the top twelve  inches of the soil.  Approximately 13,600  cubic yards of soil at
concentrations above 20 ppb dioxin as well as 105,000 cubic yards of structures and debris are estimated to
be contaminated.  No detectable levels of dioxin  have been found in the ground water or surface water at
the site thus far.  Based on the analytical results of soil samples collected in 1982, and on an advisory from
the Centers for Disease Control,  EPA determined that all residents and businesses should be relocated.   In
February 1983, EPA transferred CERCLA funds to the Federal Emergency Management Agency to  conduct
relocation activities.  The  primary contaminant of concern affecting the  soil at this site is  2,3,7,8-TCDD
(dioxin).

      The selected remedial action for the site includes: demolition and on-site disposal of all  structures and
debris remaining  at the site, excavation of dioxin-contaminated soil exceeding 20 ppb, and thermal treatment
in a temporary on-site thermal treatment unit with on-site disposal of incinerator ash, placing of clean soil
cover and revegetation over all areas with residual dioxin levels between 1 and 20 ppb, construction of a ring
levee surrounding the temporary thermal treatment unit for flood protection, interim storage of excavated soil
on-site pending  availability  of the thermal  treatment unit, and implementation of erosion controls. The
estimated total  capital  cost for  this remedial action is $48,800,000,  which includes  all costs  from  the
Minker/Stout/Romaine Creek site.

PERFORMANCE STANDARDS  OR GOALS:  Soil cleanup  levels will attain  a  1  ppb  dioxin  level at  the
ground surface and a 5 to  10 ppb dioxin level at a depth  of one foot or greater.  Thermal  treatment will
attain (99.9999 percent) destruction and removal efficiency  of dioxins  from soil.

INSTITUTIONAL CONTROLS:  Institutional controls will be established to control future land use and to
prevent future residental development.
                                                B-134

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                            ANACONDA SMELTER/MILL CREEK, MT
                                       First Remedial Action
                                          October 2, 1987
ROD ABSTRACT
      The 160-acre community of Mill Creek is located in Deerlodge County, Montana, immediately adjacent
to the Anaconda Smelter NPL site. The community of Mill Creek has been contaminated for over 100 years
with smelter emissions, fugitive emissions of flu dust  at  the  smelter, and  continued  fugitive  emissions
emanating from adjacent highly contaminated soils. Settled  flue emissions in the community of Mill Creek,
from the now defunct copper  smelting operation, contain arsenic, cadmium,  and lead.  Environmental testing
of the community, and biological testing of pre-school children led EPA to conclude that contamination in
the Mill  Creek area poses an imminent and substantial  endangerment to the  health of individuals residing
there.  In combination  with future operable units for Mill Creek, the goal of this interim remediation is to
provide adequate  permanent protection for the health of current residents and interim protection for future
short-term visitors to the area. The  primary  contaminant of concern at this site is arsenic.  Cadmium and
lead are  secondary contaminants of concern.

      The selected remedial  action for this site includes: permanent relocation  of all residents (8 homes),
with temporary erosional stabilization of disturbed areas by  establishing and maintaining a vegetative cover;
demolition, consolidation, and temporary on-site storage of debris; fencing and posting of the entire site; and
implementation of site access and deed restrictions. The estimated present worth cost for this remedial action
is $300,000.

PERFORMANCE STANDARDS OR  GOALS: Risk-based performance goals for  arsenic and cadmium  were
less than background levels and appear technically unattainable. Therefore, background levels for arsenic 0.01
ug/m  and cadmium 0.01 ug/m  will be met. The NAAQS for lead  1.5 ug/m also will be met.

INSTITUTIONAL CONTROLS:  Institutional controls will be implemented to control site access  and future
land use.
                                               B-135

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                               BRODERICK WOOD PRODUCTS, CO
                                       First Remedial Action
                                           June 30, 1988
ROD ABSTRACT
      The Broderick Wood  Products Company (BWP) site, is located in  Adams County, Colorado, and
encompasses  approximately 64 acres.  It is situated in a primarily industrial  area and is bounded on the
southwest and southeast by railroad tracks and on the north by Fisher Ditch. The site is one-half mile south
of Clear  Creek, a perennial stream.  The nearest residences are less than one-eighth of a mile north of the
property  line.  Major site features include two surface impoundments  and  a total  of 19  buildings and
structures.  Between 1947 and 1981, BWP  operated  a wood treatment facility to treat power poles,  fence
posts, railroad ties, and other wood  products.  Process wastes from the plant were conveyed through a clay
pipe to the two on-site, unlined surface impoundments, referred to as the main  and secondary impoundments
and located in the northwest  corner of the  facility. Records indicate that waste seepage was apparent just
north of the  site  and became so extensive  that the waste was burned off,  starting in 1955.  Records also
indicate that  four additional  ponds  were periodically utilized.  In August 1980, BWP submitted a RCRA
permitting application and obtained  interim status to  operate its facility but  ceased operations in November
1981. Site investigations conducted  by EPA in April  1981 and July 1982 noted several violations  of RCRA
requirements. Another site inspection in December 1982 revealed the possibility of serious contamination at
a trench  in the vicinity of the surface impoundments that reportedly had only been used for the disposal of
solid waste.  A black stain and oily puddle were noted at the bottom of the trench.  Wood treating chemicals
also  were detected  in a ground  water  monitoring well located immediately  downgradient of the surface
impoundments. A source of contamination at the site  that will be addressed in this remedial  action is a result
of a  fire in  July 1985 that  damaged  the  treatment plant  building.   Water used to  fight  the fire was
contaminated with asbestos fibers from the building  insulation.  This contaminated water was pumped  to
on-site holding vessels and some still remains in the basement of the building.  The main and  secondary
impoundments have  been identified as the major sources of site  contamination.   The main impoundment
contains  a surface layer of oil and grease, a water  layer, and a sludge layer.  The secondary impoundment
contains  primarily a  sludge layer.  The  quantity of sludge from the two  impoundments is  estimated  to be
approximately 4000 yd  and is designated as RCRA  K001 hazardous  waste.  Approximately 31,000 yd3  of
contaminated soil is  estimated to be below  the impoundments.  The primary contaminants  of concern from
the impoundments affecting the soil and ground water  are VOCs including benzene, organics including PAHs,
PCPs, dioxins, and metals including  lead.

      The selected remedial  action for  this site includes:  installation  of  access restrictions; excavation and
on-site mobile incineration of the sludge and oil in the main  and the secondary impoundments, with off-site
disposal of the residual ash; treatment of contaminated impoundment wastewater using carbon adsorption with
disposal  through  on-site evapo-transpiration or use as  incinerator quench water; excavation of the visibjy
contaminated soil beneath the impoundments, and  on-site incineration if the volume is less than  2,500 yd ,
or on-site storage for further studies, if the volume is greater than 2,500 yd ; filtration of water from  the
facility area to remove asbestos fibers, and  treatment  using carbon adsorption, with disposal through on-site
evapo-transpiration or use as incineration quench water; and ground water monitoring. The estimated present
worth cost for this remedial action ranges between $2,264,000 and $3,603,200.

PERFORMANCE STANDARDS OR GOALS:   Cleanup goals  will meet specified BOAT levels  for RCRA
K001 sludge  as determined by testing the incinerator ash to ensure that  concentrations do not  exceed the
following levels:  zinc 0.066  mg/1  (TCLP), lead 0.53 mg/1  (TCLP),  copper 0.71  mg/1  (TCLP), xylenes
0.162 mg/kg, toluene 0.143 mg/kg,  pyrene  7.28 mg/kg,  phenanthrene 7.98  mg/kg, PCP 36.75 mg/kg, and
napthalene 7.98 mg/kg.  Wastewater contaminants will be treated to non-detectable levels to comply with State
standards.  If these levels cannot be met, State standards will be waived and contaminants will be treated to
MCLs.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-136

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                     CALIFORNIA GULCH, CO
                                        First Remedial Action
                                           March 29, 1988
ROD ABSTRACT
      The California Gulch site is located in Lake County, Colorado, approximately 100 miles southwest of
Denver.  The study area for this first remedial action encompasses an 11.5 m  watershed, which includes the
city of Leadville, and which drains along California  Gulch to the Arkansas River.  Between 1859 and 1986,
the area was extensively mined for gold, lead, silver, copper, zinc, and manganese.  Because of these mining
operations,  the Yak  Tunnel was constructed to de-water mines and facilitate  mineral exploration and
development.  Studies indicate  that the Yak Tunnel discharges a  combined  total of 210 tons per year of
cadmium, lead, copper, manganese, iron, and zinc into California Gulch, which drains into the Arkansas River.
Both California Gulch and the Arkansas River are used by the public for recreation; the Arkansas River is
heavily  used for irrigation,  livestock watering, public water supply, and fisheries as well.  Surface water
contamination is the major impact of the Yak Tunnel discharge.  Heavy metal migration through surface water
has also caused ground water and sediment contamination.  Primary contaminants of concern affecting the
surface  water, sediments, and ground water are cadmium, copper, lead, and zinc.

      The selected remedial action for this  site includes:  construction of surge ponds at the portal of Yak
Tunnel  to protect  the California  Gulch site  and  the Arkansas  River from accidental release of acid water,
sludge,  and sediments; construction  of concrete  plugs at  locations in the tunnel to reduce migration of
contaminated water and reduce the extraction of  metals from raw mineral ore; sealing shafts and drill holes,
diversion  of surface water away from tunnel  recharge  areas,  and  grouting of  highly fractured rock;
implementation of a monitoring program to  detect leaks,  seeps or migration  of contaminated ground water;
and installation of  an interim treatment plant to treat ground water, which will be pumped to control surface
seeps and migration of contaminated surface water. The estimated capital  cost of the  selected remedy is
$11,982,770  with annual O&M costs of $460,307.

PERFORMANCE STANDARDS OR GOALS: This operable unit invokes an interim remedy waiver.  Because
of other sources affecting surface water contamination, the remedy does not expect to attain chemical-specific
cleanup goals  for  surface  water.  Response  actions  in subsequent  operable units, in combination with this
remedy, will attain a level or standard  of control at  least equivalent to ARARs.

INSTITUTIONAL  CONTROLS:  Not applicable.
                                               B-137

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                              CENTRAL CITY/CLEAR CREEK, CO
                                      Second Remedial Action
                                          March 31, 1988
ROD ABSTRACT
      The Clear Creek/Central City site is located approximately 30 miles west of Denver in  Clear Creek
and Gilpin Counties, Colorado.  The site consists primarily of acid mine drainages from five mines/tunnels
and adjacent milling and mining wastes.  Currently,  acid mine drainage, and runon  and runoff from the
tailings and waste  rock piles have affected downstream surface water quality.  In addition to the direct
discharge from the mine tunnels, contaminated water may enter Clear Creek and North Clear Creek during
overland sheet flow.  This occurs during rapid snowmelt and storms.  The resulting surface flow across the
tailings and waste  rock piles dissolves soluble minerals  and transports particulate tailings  and waste  rock
materials into the  creeks.  All this results in  elevated creek acidity  and metal loads.  The introduction of
tailings and waste rock into the creeks could also occur due to catastrophic collapse of tailings and waste rock
piles during a flash flood, or as a result of undercutting of the base of the pile under any flow regimen.  The
discharges from the five tunnels were addressed in the first remedial  action operable unit  for this site.  The
primary contaminants of concern for human receptors in surface water include: aluminum,  arsenic, cadmium,
chromium (IV), lead, manganese, nickel,  and silver.  For aquatic receptors, the above list expands to include:
copper, fluoride, and zinc.

      The selected remedial action for  this  site includes:   slope stabilization at the Big Five Tunnel and
Gregory Incline; monitoring of the gabion wall  at the Gregory Incline;  and run-on control at the Argo Tunnel,
Big Five Tunnel, Gregory Incline, National Tunnel, and the Quartz Hill Tunnel. The estimated present worth
cost for this remedial action is $1,049,600.

PERFORMANCE  STANDARDS  OR GOALS:  The  selected  interim remedy requires the exercise of the
"interim remedy" from  the contaminant-specific ARARs listed  in the  FS.

INSTITUTIONAL  CONTROLS:  Not applicable.
                                               B-138

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    INDIAN BEND WASH, AZ
                                       First Remedial Action
                                         September 21, 1988
ROD ABSTRACT
      The Indian Bend Wash site (IBW) encompasses 13 square miles in Scottsdale and Tempe, Arizona.
The portion of the site addressed in this remedial action, the Scottsdale Ground Water Operable Unit, covers
approximately eight  square miles within the Scottsdale city limits.  The Indian Bend Wash, a flood protection
mechanism, runs north - south through the site and supports recreational uses. Ponds in the wash are used
as a water collection system. The land use of this area is primarily residential with approximately 30 percent
used for commercial, light industrial, and developed recreational purposes.  The  resident population of
Scottsdale was 115,500 in 1986, and is expected to reach 129,500 by 1990. Approximately 70 percent of the
City of Scottsdale's  municipal water currently is  supplied by ground water.   Future population  growth will
require greater  use  of ground water resources, particularly from the contaminated areas.  In 1981, TCE was
discovered  in the ground water from several  City  of Scottsdale and  City of Phoenix  municipal wells at
concentrations exceeding  the Arizona Department of Health Services action levels.   Several facilities within
the site  boundaries  have  records of past  use of TCE in their manufacturing process.  Seven of the  12 city
wells within the boundaries of  this operable unit have levels  of VOCs exceeding primary drinking water
standards.  One of the seven is equipped with a VOC treatment facility and is used as a potable water supply
source.  The  other  six wells are  currently off-line.  The site was placed on the NPL in 1982.  The primary
contaminants of concern affecting the ground water  are VOCs including TCE and PCE.

      The selected remedial action for this  operable unit of the site includes:  extraction of ground water
by pumping City of Scottsdale Wells No. 31, 71,  72, and 75 at a minimum of 75 percent of their historical
capacities; treatment of ground water using packed column aeration to transfer the VOCs from the water to
air, with vapor phase GAC adsorption to remove VOCs from the air waste stream; and distribution of the
treated water to the City of Scottsdale municipal water system.  This remedial action  addresses ground water
contamination only  in the Middle and Lower Alluvium Units beneath the north portion of IBW within the
Scottsdale City limits.  Contamination beyond these limits in the ground water of the Upper Alluvium limit
and in the soil will be addressed in subsequent remedial actions for the IBW site. The estimated total capital
cost for  this operable unit is $4,008,000 with an estimated annual O&M cost of $520,000.

PERFORMANCE STANDARDS  OR GOALS: Treatment of the ground water will reduce contamination to
levels below MCLs  and State action levels.  Specific treatment goals include  TCE 5 ug/1 (MCL), TCA 200
ug/1 (MCL), DCE 7 ug/1 (MCL), and PCE  0.67 ug/1.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-139

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                LORENTZ BARREL & DRUM, CA
                                       First Remedial Action
                                        September 25,  1988
ROD ABSTRACT
      The 5.4-acre Lorentz Barrel & Drum (LB&D) site is located in San Jose, California, about 0.25 mile
from San Jose State University.  The site lies  directly above a major source of potable ground water in the
south San Francisco Bay area, with three public water supply well fields within one mile of the site.  In 1947
the Lorentz family began a drum recycling operation on 10.5 acres of land at the site.  Currently, 4.5 acres
are capped  with tar  and gravel  but contain stored  drums; 0.75  acre includes the reconditioning facilities.
Drums containing residual aqueous wastes, organic solvents, acids, oxidizers,  caustic residues, and oils were
received for recycling.  During the early years of operation, portions of the  site were  also leased to other
companies.  Between 1950 and 1978, a drainage ditch north of the drum processing building carried process
wastes to a large  sump  and other ponding  areas  on-site.  Prior to 1968, wastes from the  sump were
discharged  to a storm  drain system.   Sometime  between  1968 and  1971, the discharge  was diverted to a
sanitary sewer, and investigations indicate that this  discharge occurred until 1984.  After this  time, liquid
wastes were evaporated, drummed, and disposed  of as hazardous waste along with incinerator ash, residual
liquids, and sludge.  Subsequent surface run-off was collected and recycled in the hot caustic  drum wash.
Since 1981, several investigations have revealed soil and ground water  contaminated with numerous metals,
organics, and PCBs.  Removal of drums, stored hazardous materials, and highly contaminated soil has been
conducted at the site. This remedial action will address the off-site contaminated shallow ground water. On-
site contaminated soil,  and additional shallow and deep ground  water remediation will be addressed in a
subsequent remedial action. The primary contaminants of concern affecting soil and ground water are VOCs,
including benzene, PCE and TCE, other organics including PCBs and pesticides, and metals including arsenic
and nickel.

      The selected  Expedited  Response Action  for this site includes: on-site  ground water  pump  and
treatment using ozone/UV for organic removal and ion exchange for nickel removal, with discharge of treated
water to  a  local creek.   The estimated present worth cost for this remedy is $3,238,000 with annual O&M
costs of $198,000.

PERFORMANCE STANDARDS OR GOALS: Treatment of ground  water will attain levels at or below
MCLs and NPDES discharge limit requirements.  Specific treatment levels include:  benzene, PCE, and TCE
5.0 ug/1 (MCLS), PCBs 0.065 ug/1, and arsenic 0.23 ug/1.  PCBs and  pesticides will be removed  to detection
limits.

INSTITUTIONAL CONTROLS:   Not applicable.
                                               B-140

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                        MGM BRAKES, CA
                                     First Remedial Action-Final
                                         September 29,  1988
ROD ABSTRACT
      The MGM  Brakes  site consists of a five-acre plot containing an automotive brakes casting plant, a
paved area surrounding the plant, and an open field.  It is located in the city of Cloverdale, California, in
Alexander Valley,  approximately 80 miles north of San Francisco.  Forty homes, an apartment complex, a
church,  an animal grazing area, and several construction companies  exist within a half-mile radius  of the
site.  In addition,  a 200 unit housing development is under construction immediately adjacent to the site.
Surface  water drainage from the site flows into Icaia Creek which flows into the Russian River. From 1965
until 1972, wastewater containing PCBs was discharged  onto site property.  Wastewater containing ethylene
glycol was disposed on-site between  1972 and 1981.  The ethylene elycol acted as a co-solvent with  water,
facilitating the transport of PCBs hi  soil. Approximately 13,510 yd  of soil within a 3-acre area have been
contaminated with PCBs at  concentrations up to  4500  ppm.  The majority of contamination  is present at
depths of less than 5 feet (although contamination to 29 feet was found in one area).  In addition, VOCs have
been detected in ground water from wells on and  near the site.  However, the source of this contamination
is  unknown.  The  primary contaminants of concern affecting ground water are VOCs including  TCE and
benzene.  The primary contaminants of concern affecting soil, sediments, surface water, and air are PCBs.

      The selected remedial action for this site includes: dismantling of the MGM Brakes process building;
crushing of concrete  slab, and  excavation  of soil and of  contaminated  sediments in the drainage ditch
containing PCBs at levels greater than or equal to  10 mg/kg, with disposal in an off-site California regulated
Class II landfill if below 50 ppm and a TSCA-approved  landfill if above 50 ppm; determination and removal
of VOC-contaminated soil and off-site RCRA disposal;  treatment of dewatered ground water for PCBs and
VOCs through use of an on-site mobile treatment unit  and discharge to a publicly owned treatment works
(POTW); soil replacement,  regrading, compaction, and revegetation;  off-site ground water monitoring to
determine extent of VOC contamination; and  development of additional remedial  measures,  if warranted.
The estimated capital cost for this  remedial action is $5,369,300 with no annual O&M costs.

PERFORMANCE  STANDARDS OR GOALS:  Soil  containing  greater than or equal to 10 mg/kg PCBs
(equal to 10"5 cancer risk) will be  removed.  Ground water will be restored to MCL or other health-based
levels such that the total risk from VOC contamination at the site boundary does not exceed  10" . Discharge
levels of treated  ground water to the local POTW will meet the requirements of the California North Coast
Regional Water  Quality Control Board's Water Quality Control Plan.

INSTITUTIONAL  CONTROLS:  Implementation of institutional controls is not necessary because the selected
remedy  will not result in hazardous substances remaining on-site above health-based levels.
                                               B-141

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                 MOTOROLA 52ND STREET, AZ
                                        First Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The Motorola 52nd Street site is located in the eastern part of the City of Phoenix, Maricopa County,
Arizona.  The site is bounded by the Phoenix Military Reservation and mixed  residential and commercial
neighborhoods. The site is currently owned by Motorola, Inc., which operates a manufacturing facility at the
site using solvents for various manufacturing processes. In January 1983, Motorola tested some underground
storage  tanks used to store virgin solvents for leaks and determined that a 5,000-gallon tank containing TCA
was leaking.  Subsequently, Motorola conducted a preliminary investigation, which indicated soil and ground
water contamination on the plant site and ground water contamination off-site to the west. Motorola initiated
an on-site ground water treatment program in 1986, which included treatability testing, design, and installation
of a Pilot Treatment Plant (FTP), treatment of ground water, and beneficial use of the effluent in the plant's
air  fume scrubbers.   The PTP is still in  operation.  The selected remedy for this ROD requires partial
cleanup of on-site and  off-site organic  solvents contamination in  the soil  and alluvium  groundwater.  A
subsequent remedial action will address cleanup of all on-site and off-site contamination in the soil, alluvium
ground  water, and the bedrock underlying the alluvium.  The primary contaminant of concern affecting the
soil and ground water is TCA.

      The selected remedial action for this  site  includes:  on-site  soil-gas extraction and treatment using
granular activated carbon systems; pump and treatment of on-  and off-site ground water with treatment on-
site and use of the treated ground water in site manufacturing processes; and ground water monitoring.  The
estimated present worth cost for this remedial action is $7,600,000 with annual O&M costs of $700,000.

PERFORMANCE STANDARDS OR GOALS: Ground water cleanup will meet relevant State and Federal
standards including Maricopa County Pollution  Control-'discharge standards.  Individual contaminant goals
were not specified.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-142

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                  OPERATING INDUSTRIES, CA
                                      Second Remedial Action
                                         November  16, 1987
ROD ABSTRACT
      The Operating Industries, Inc., (Oil) site is a 190-acre landfill located in Monterey Park, California.
The City of Montebello borders the southern parcel of the landfill and has a population of 52,929 residents.
Several residences are located immediately adjacent to  the landfill boundaries.  Between 1948 and 1984, the
landfill was used for the disposal of municipal and industrial waste (some of which  would currently be
classified as hazardous waste). Between 1976 and 1983, the landfill was permitted to receive liquid hazarous
waste and accepted over 200  million gallons of manifested liquid waste.  Over its 36-year life span, the Oil
landfill has accepted several  types of waste including:  residential and commercial refuse; water-insoluble,
nondecomposable inert solids; liquid wastes; various hazardous wastes including waste water treatment sludge
from  production  of chrome  oxide green  pigment;  and slop oil emulsion soh'ds and tank bottom  sludges
(leaded)  from petroleum refining operations.  Both landfill gas and leachate are generated at the Oil site.
Several gas and leachate collection systems were constructed by the owners of Oil during the early 1980s to
partially control landfill gas and prevent surface seepage of leachate. GSF, Inc., also constructed a commercial
methane recovery system at the site and began extracting gas from the landfill for processing and sale in 1979.
Leachate was redisposed at the landfil until October 1984; since then, collected leachate has been stored in
tanks on-site and transported  to a permitted off-site treatment facility. The collected leachate contains VOCs.
EPA  took over day to day operations and  maintenance of the site and existing site systems as an emergency
response action in May 1986.  EPA has conducted a number of the emergency actions to mitigate some of
the potential threats to public health and the environment which are posed by the site.  GSF, Inc., abandoned
their gas extraction operations in the spring of 1987, and EPA has operated the GSF system since that time.
In July 1987, EPA signed a Record  of Decision addressing site control and monitoring activities, which have
since  been conducted by EPA as a remedial action.  This ROD is designed to address the approximately
10,000 gallons of leachate that  are  expected to be  collected before implementation of a final site remedy.
The leachate generated contains VOCs including benzene, TCE, toluene, and vinyl chloride.

      The selected remedial action for this site includes:  on-site treatment of leachate and other collected
hazardous liquids by air stripping and granular activated carbon adsorption in a facility constructed  at  on-
site location B, with discharge to the Los Angeles County Sanitation District sewerage system for treatment
at a  POTW.  The estimated five-year  capital cost for this remedial action  is $1,900,000  with estimated
five-year annual O&M of $700,000.

PERFORMANCE  STANDARDS OR GOALS:  Leachate will be treated to achieve the 10"6 health-based
Los Angeles  County Sanitation District (LASCD) Industrial Discharge Requirements.  Individual effluent
discharge limits include: arsenic 3.0  mg/1,  chromium 2.77 mg/1, copper 3.38 mg/1, zinc 2.61 mg/1,  oil and
grease 10.0 mg/1, total toxic organics 1.0 mg/1, and vinyl chloride 15 ug/1.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-143

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  OPERATING INDUSTRIES, CA
                                       Third Remedial Action
                                         September 30, 1988
ROD ABSTRACT
      The Operating Industries Inc. (Oil) site is a 190-acre landfill located in Monterey Park, California, 10
miles east of Los Angeles.  Northwest and east of the site the land use is primarily industrial; residential units
are located to the southwest, east, and west of the site.  There are approximately 53,000 residences within
a three-mile radius of the site.  Available data indicate that 2,150 people live within 1,000 feet of the  landfill.
Disposal activities  at the site began in October 1948 by the Monterey Park Disposal Company (MPDC) who
used the site as a municipal landfill  on behalf of the City of Monterey Park.  In 1952, the site and additional
land,  totalling 218 acres, were  purchased by OIL   The  landfill was permitted to accept household refuse,
organic  refuse, scrap metal, non-decomposable  inert solids, and certain types of liquids.  In 1964, the State
of California purchased 28 acres of  the land owned by Oil  to construct the Pomona Freeway, which  divided
the site  into two sections.  In 1975,  Monterey Park City limited solid waste disposal to a  130-acre section of
the landfill and a year later restricted disposal of liquids to a 32-acre section of the landfill.  In April 1983,
Oil ceased accepting all liquid wastes; disposal  of all solid  wastes ended in October 1984.  EPA currently is
performing operation and  maintenance  of the  existing leachate collection system, perimeter gas extraction
system,  and interior gas extraction system. This  remedial  action addresses only the issue of landfill gas (LFG)
migration control and destruction. Final cover, leachate collection, ground water and soil contamination, slope
stability, and final closure  will be addressed  in subsequent remedial  action.  The primary contaminants of
concern affecting the air are methane and VOCs including benzene, PCE, TCE,  and  toluene.

      The selected remedial action at the site includes:   installation of perimeter LFG extraction wells,
pile-driven wells on the top deck of  the landfill,  shallow and deep slope wells to control intermediate-to-deep
subsurface migration  at the perimeter,  and integrated perimeter  and interior  LFG headers; utilization of
existing  gas extraction wells and gas monitoring probes; installation of multiple  completion monitoring wells
at the property boundary, landfill gas destruction facilities  and an automated control station for the gas control
system;  and installation of abovegrade condensate sumps to collect condensate from gas headers, leachate
pumps in gas wells to de-water saturated zones, and abovegrade leachate sumps.  The selected remedial action
for the  North Parcel system includes:  installation of six single completion extraction wells to the depth of
the refuse and installation of 1,500 feet of header lines. The estimated present worth for this remedial action
is $73,000,000  with an  annual O&M cost of $2,340,000.

PERFORMANCE  STANDARDS OR GOALS:  This remedy will attain State-required levels for vinyl chloride
ambient concentrations of 10 ug/1 over a 24-hour period, carbon monoxide emissions of 2,000 mg/1, and sulfur
dioxide  emissions of 500 mg/1.  The risk of fire or explosion due to landfill gas accumulating off-site will be
eliminated by controlling methane  concentrations  to  less than five percent of the landfill boundary. The
leachate and condensate that will be collected from the gas control system will be treated to levels established
by the POTW pretreatment requirements.

INSTITUTIONAL CONTROLS:  Not applicable.
                                                B-144

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                      ORDOT LANDFILL, GU
                                    First Remedial Action - Final
                                         September 28, 1988
ROD ABSTRACT
      The Ordot Landfill site is located on the Island of Guam. The landfill is in a volcanic upland region,
where site  runoff flows directly  into the adjacent Lonfit River.  Water wells have not been drilled in the
volcanics near the landfill.  There is concern, however, that a  suspected fault near the landfill may provide
a hydrologic connection between the contaminants  at  Ordot Landfill and  Guam's  major drinking water
acquifer located in the northern limestone province of Guam. The landfill is presently managed and operated
by the Guam Department of Public Works, and has  been receiving uncontrolled municipal  wastes since
before World War II. Because it is the only major public waste disposal site  on Guam, it has received some
hazardous waste during its history, including spent industrial and commercial chemicals, PCB-contaminated
oils from transformers, and perhaps munitions.  The facility uses almost the entire 47-acre waste disposal area,
with only approximately 4 to  7 acres of the oldest portion of the landfill not currently in use.  The current
depth of disposed wastes is approximately 100 feet.  In March 1986, EPA  found Ordot Landfill in violation
of the Clean Water Act for discharging landfill leachate to the Lonfit River without an NPDES  permit. The
1987 initial site  characterization study concluded that surface flow  through the landfill is the source of
leachate, the site is hydrologically isolated from the island's sole source aquifer, there is an absence of organic
contaminants, inorganic contamination is below the appropriate MCLs, and no air quality problems exist. The
study concluded that current  threats to human health and the environment are a result  of  poor  landfill
operation practices and  not a  result  of the few acres of the landfill which  are no longer in  operation.  The
primary contaminants of concern affecting the ground water and surface water  include iron  and manganese.

      The selected remedial  action for this site is the no action alternative.  EPA concludes that threats to
human health and the environment  can best be mitigated through addressing operation and maintenance of
the  landfill, and that the appropriate mechanism for implementing these controls is through enforcement of
the  Clean Water Act.  Further, EPA concludes 'that  any remedial action to  address the inactive portion of
the  landfill  would be jeopardized  or nullified  unless operation practices  at the active  disposal areas  are
improved.  No costs  are associated with the  no action alternative.

PERFORMANCE STANDARDS  OR GOALS:   Not applicable.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-145

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                         SAN GABRIEL VALLEY (AREAS 1, 2, and 4), CA
                                      Second Remedial Action
                                         September 29, 1988
ROD ABSTRACT
      The San  Gabriel  Valley sites  consist  of four  large areas of ground water contamination located
approximately 10 to  20 miles east of Los Angeles in Los Angeles  County, California.  The sites include
industrial, commercial, residential,  and undeveloped  areas.   The  contaminated ground  water underlies
significant portions of several cities and outlying areas of the San Gabriel Valley, and appears to be the result
of inadequate handling and disposal of industrial solvents by dozens of industrial/commercial facilities.  The
Main San Gabriel Ground Water Basin, which underlies the San Gabriel Valley, provides over 90% of the
water supply for  over 1 million people. Ground and surface water, including the San Gabriel and Rio Hondo
rivers, flow predominantly to the southwest through Whittier Narrows. Drainage through Whittier Narrows
enters Central Basin  to the south, another major water supply source. Ground water discharges to surface
water hi several  locations, including a  creek in the southwest portion of the  valley and the San Gabriel and
Rio Hondo rivers near Whittier Narrows.  Ground water contamination by VOCs has been detected in over
50 wells at concentrations above the action levels established by the California Department of Health Services.
This ROD addresses  contamination in the Bartolo Well Field, a private water utility, owned and operated by
Suburban Water Systems (SWS) and located  along the east side of the  San Gabriel River in the Whittier
Narrows area. The Bartolo Well Field consists of four public water supply wells that provide over 55 percent
of the water supply for approximately  17,000 commercial and residential water customers in SWS's Whittier
Service  District.  They were first  identified as contaminated in the the fall of 1986.  This action is the first
phase of a larger remedial action  planned for the Whittier Narrows area  and addresses only a small part of
the contamination in  the San  Gabriel Valley Areas  1, 2, and 4 sites.  The objective  of this action is to
partially control the movement and spread of contaminants in the Whittier Narrows area of the San Gabriel
Valley,  thereby  contributing to aquifer restoration of the San  Gabriel Valley Areas  1,  2, and  4 sites.
Additionally, this action will address the potential public health threat  posed by the SWS's Bartolo Well Field.
The  primary  contaminants of concern  affecting the  ground water  are VOCs including PCE and TCE.

      The selected remedial action for  this site includes:  on-site ground water pump and  treatment using
an air stripping system equipped with  air emissions controls, with subsequent discharge to the utility's water
distribution system; floodproofing the treatment facility; and ground  water monitoring.

PERFORMANCE STANDARDS OR GOALS: Ground water treatment will attain a cumulative 10"6 cancer
risk  level and meet  MCLs  for TCE 5 ug/1 and  DCE  7 ug/1.  State  action levels will  be  attained by
remediating PCE to below 1.0 ppb.

INSTITUTIONAL CONTROLS:  Not  applicable.
                                               B-146

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                      Progress Toward Implementing Superfund:  Fiscal Year 1988
                                SELMA PRESSURE TREATING, CA
                                     First Remedial Action - Final
                                          September 24,  1988
ROD ABSTRACT
      The Selma Pressure Treating site is located in Selma, California, 15 miles south of the City of Fresno.
The site encompasses approximately 18 acres, including a three to four-acre wood treatment facility and 14
acres of adjacent vineyards that were used for site drainage.  Land use in the vicinity of the site includes
agricultural, residential, and industrial areas, with 12 residences and businesses located within 0.25 mile. The
ground water resources in the area have been classified as a Sole-Source Aquifer and a current drinking water
source with other beneficial uses. Wood preserving activities using pentachlorophenol (PCP) were conducted
at the site from 1942 until 1965 under a series of owners.  In 1965, a new facility was constructed converting
operations  to a pressure treating process using chemical preservatives. Prior to 1982, wastes generated from
spent retort fluids and  sludges were discharged to drainage and percolation ditches, dry wells, and an unlined
pond and sludge pit, as well as  onto open ground and the adjacent vineyards.  An inspection conducted by
EPA in 1981 raised concerns about the potential for ground water contamination, and as a result the company
was required to modify its operations to minimize the potential for contamination.  The total volume of soil
requiring remediation is approximately 16,100 yd  . The primary contaminants of concern affecting the ground
water and soil are organics including  dioxin and phenols,  and metals including arsenic and chromium.

      The  selected remedial  action for this site  includes:   ground  water pump and  treatment  using
precipitation, coagulation,  and flocculation with reinjection into the aquifer or off-site discharge; soil excavation
and solidification/stabilization with replacement in excavated areas and capping fixed soil with a RCRA cap;
ground water and soil monitoring for  approximately 30 years; and long-term access and land use restrictions
for fixed areas and  short-term institutional controls for ground water use.  The estimated present worth cost
for this  remedial action is $11,280,000 with annual O&M  of $1,300,000.

PERFORMANCE STANDARDS OR GOALS:  Soil cleanup will attain the risk-based goals of dioxin/furan
1 ug/kg and arsenic 50 mg/kg to protect ground water.  Ground water treatment will meet the  State MCL
for chromium of 50 ug/kg.

INSTITUTIONAL CONTROLS:  Long-term access and land use restrictions will be placed on areas of fixed
soil, and short-term institutional controls will be established to prevent use of contaminated ground water until
remediation is complete.
                                                B-147

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                   SOUTH BAY ASBESTOS, CA
                                    First Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The South Bay Asbestos (SBA) site is located at the northern end of the Santa Clara Valley at the
southernmost extent of San Francisco Bay, in Alviso,  California. The site is within an area of approximately
330 acres, and is comprised of a mixture of residential, commercial, light industrial, and agricultural land  uses.
Approximately 1,700 residents live in Alviso.  The site is comprised of a ring levee, which extends around the
community of Alviso on the east, north, and northwest.  It is approximately four to twelve feet in height, two
miles in length, has a trapezoidal shape, and covers an area of about eight acres. A narrow path exists along
the crest of the levee.  The levee was built by the  City of San Jose  in 1983 during  a major flood caused by
the Coyote Creek and the Guadalupe River.  It lies within the 100-year flood plain of the  Guadalupe River
and was constructed on portions of wetland areas adjacent to the community of Alviso.  It also abuts wetland
areas next to a national wildlife refuge near Alviso. In August 1983, an excavation occurred on property
owned by the City of San Jose involving the construction of an outfall structure at the Guadalupe River levee.
The excavation revealed asbestos  contamination ranging from 20 to  40 percent by area.  Contaminated soil
was  removed between August  and December 1983.  A September 1983 soil sampling  also  revealed the
presence of asbestos contamination throughout the community of Alviso, including the ring levee.  As a result,
EPA sprayed the ring levee with a polymer dust suppressant to control asbestos dust in May 1986, in  1987,
and  again in July 1988.  The primary contaminant  of concern affecting the soil is asbestos.

      The selected remedial action for the  ring levee includes:  stripping and rough  grading  of the levee;
placement of  a  compacted soil layer  and a top  soil cover followed  by revegetation to prevent  erosion;
alteration of the  side  slopes  and construction of  a  three-foot  wide  path  on  the  crest of the levee;
implementation  of strict  asbestos/dust control  measures  during  the entire  construction operation;  and
implementation of deed restrictions.  The estimated present worth cost for this remedial action  is $2,374,700
with annual O&M of $19,000.

PERFORMANCE  STANDARDS  OR  GOALS:  The selected remedial action will be protective  of public
health by creating a barrier to  control release of the asbestos fibers.  No specific standards or goals  were
established.   Compliance with  OSHA  Worker  Exposure  Standards  will  be  maintained  during the
implementation of the remedy.

INSTITUTIONAL CONTROLS:  Deed restrictions will be implemented to  prevent the disturbance of the
soil cover and possible release of asbestos fibers.
                                                B-148

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                         TUCSON INTERNATIONAL AIRPORT AREA, AZ
                                        First Remedial Action
                                           August 22, 1988
ROD ABSTRACT
      The Tucson International Airport Area  (TAA) site encompasses  sections  of southwest Tucson and
adjoining lands south of the city in Pima County, Arizona.  The  site is located  in the Tucson Basin and
includes industrial, commercial, residential, and undeveloped areas, as well as the Tucson International Airport,
the U.S. Air Force Plant #44 (AFP44), and part of the San Xavier Indian Reservation.  The Santa Cruz
River borders the site to the west.  The ground water system in the Tucson Basin has been designated a
Sole-Source Aquifer.  Before the discovery of ground water contamination in the TAA, wells within the site
boundaries provided water for over 47,000 people.  At least 20 facilities have operated in the TAA since 1942.
These include aircraft and electronics facilities which discharged waste h'quids directly to surface soil; fire drill
training areas where  uncombusted  residual  wastes from  training operations were left in unlined pits; and
unlined  landfills which received various  wastes from several sources.   The first indications of ground water
contamination in  TAA appeared in the early 1950s, when elevated levels of chromium were detected in a
municipal supply  well adjacent to AFP44 in the southern portion of the site,  and residents in another area
complained of foul-smelling water from private supply wells. In 1976, a well was closed at AFP44 by the
State because of  high levels of chromium.   By 1981, additional sampling by the Air Force and EPA had
indicated the presence of VOCs in the ground water. Consequently, in 1981, the City of Tucson began closing
all municipal wells that exceeded the State  Action Level  for the principle  contaminant TCE, and notified
private well users of potential risks. The site was divided approximately in half along Los Reales Road, with
the Air  Force addressing contamination to the  south  and EPA addressing contamination to the north.  In
1987, the Air Force began operating its ground water pump and treatment system using ion exchange and
packed  column aeration  followed by reinjection into the aquifer.  This ROD addresses the ground water
contamination in  the northern portion of the site, which together with the Air Force remedial ground water
system constitutes the overall ground water remedy for the site.  The northern portion of the site has been
divided into two discrete areas, A and B.  Area A lies west of the airport and extends approximately 3.5 miles
to the northwest  in the  direction  of ground water flow,  and is generally less than a  mile wide.  Area  B
consists of two smaller separate areas north of the airport.  If further investigations indicate that there is soil
contamination which  is a source  of continuing  ground water contamination,  a  ROD  will be developed to
address  soil remediation.  The primary contaminants of concern affecting ground water are  VOCs including
TCE, benzene,  and xylenes.

      The selected remedial action for this site  includes: ground water pump and  treatment of Areas A and
B using packed column aeration, followed by discharge of treated water to the municipal water distribution
system and treatment of  emissions from the treatment process using granular  activated carbon, if necessary.
The estimated present worth cost for this remedial action  is between $7,328,000 and $7,820,000 with annual
O&M between $393,000  and $450,000 for years  1-20.

PERFORMANCE STANDARDS OR GOALS:  Ground water cleanup levels will attain an  overall  excess
cancer risk of 10   by remediating TCE  to 1.5 ug/1.  This will reduce the levels of other contaminants below
their respective MCLs, State Action Levels,  and 10"6 excess cancer risk concentrations.

INSTITUTIONAL CONTROLS:  Not applicable.
                                               B-149

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                           COMMENCEMENT BAY/NEARSHORE, WA
                                        First Remedial Action
                                         December 30, 1987
ROD ABSTRACT
      The  Tacoma  Tar  Pits  site  covers  approximately 30  acres  within  the  Commencement  Bay
Nearshore/Tideflats site in Tacoma, Pierce County, Washington.  The tar pits lie between the Puyallup River,
the city,  and Wheeler - Osgood Waterways.  These bodies of water are not used as a water supply, but
support extensive fish and shellfish populations.   Currently there is concern for the site's impact on surface
water quality and many local industries that use ground water from on-site wells.  In 1924, a coal gasification
plant began operations, and continued until 1956, at which time they were terminated due to the availability
of natural gas.  During these years, waste materials  from the coal gasification process were disposed of on-
site. Contained  in the waste materials, were a wide variety of organic compounds  and heavy metals. From
1965 to 1966, the plant was dismantled and demolished.  Most of the metal  structures were removed from
the site;  however, all  demolition debris and below grade structures were left in place, including tanks and
pipelines containing tars.  In 1967, a metal recycling company  began operating at the site.   Recycling of
automobile batteries introduced acid, heavy metals, lead,  and PCBs to the soil. Several studies conducted by
EPA and the Washington State Department of Ecology between 1981 and 1983 found contaminants derived
from the coal gasification process.  The primary contaminants of concern affecting surface water and soil
include:  benzene, PAHs, PCBs, and lead.

      The selected remedial action for this site  includes:  excavation of all contaminated soils exceeding 1
percent total PAHs and all surface soils exceeding a 10    lifetime cancer risk level, with stabilization of all
excavated soils in a polymer/cement mixture; capping of the stabilized matrix with asphalt; channeling and
managing of surface waters; ground water monitoring;  and removal and treatment of ponded water.  The
estimated present worth cost  for this remedial action is $3,400,000.

PERFORMANCE STANDARDS OR GOALS:  All soils at a depth equal to  or less than three feet will be
treated to a 10"6 lifetime cancer risk. This equals 1 mg/kg for  PCB (consistent with TSCA regulations), 1
mg/kg for PAHs, and 56 mg/kg for benzene.  Surface soil containing more  than  166 mg/kg lead will also
be treated.  All other  soil exceeding 10,000 mg/kg PAH will be excavated and treated  in accordance with the
State law for the designation of extremely hazardous waste.  These standards will be  re-evaluated for technical
feasibility when the Remedial Action is undertaken.

INSTITUTIONAL CONTROLS: Land use restrictions will be implemented.
                                               B-150

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                             COMMENCEMENT BAY/TACOMA, WA
                                    First Remedial Action - Final
                                           March 31, 1988
ROD ABSTRACT
      The Commencement Bay/Tacoma  site is a  190-acre industrial/municipal  landfill located in Pierce
County, Tacoma, Washington.   The landfill is operated by  the  City  of Tacoma Refuse Utility and  is
surrounded  primarily by residential development  and  open land, with some commercial and industrial
development.  Several utilities (i.e., sewer,  water, and storm) pass through the site. An aquifer beneath the
site provides drinking water to the Town of Fircrest and the City of Tacoma, both of which have wells near
the landfill.  The aquifer is also used by private individuals for their domestic water supply.  Ground water
flows predominantly to the southwest toward Leach Creek, which  lies approximately 0.25 mile west of the
landfill. Consequently, wetlands downstream  of the landfill could potentially be exposed to contaminants in
the surface  water  and ground water.   The Tacoma  landfill began  operations in  1960,  receiving only
nonhazardous  wastes including assorted municipal and industrial wastes, construction and demolition wastes,
and bulk waste.  To date, about four million tons of refuse have been deposited at the landfill to depths of
20 to 80 feet.  Although  the landfill does not accept hazardous wastes for disposal, it did  receive wastes in
the 1960s and  1970s that have since been designated as hazardous substances. In 1983, investigations by EPA
revealed the presence of hazardous  compounds in the ground water and soil near the landfill.  Subsequent
investigations indicated that the ground water is contaminated with  VOCs. In response, the City of Tacoma
connected affected residences to the public water system.  In 1986, accumulation  of landfill gas in a utility
vault adjacent  to the landfill resulted in a minor  explosion.  A field survey was initiated to evaluate the extent
of off-site gas  migration, and based on this survey a gas extraction system was constructed to extract, collect,
and combust the gas.  Gas samples collected at  the  landfill revealed high levels of VOCs.  The  primary
contaminants affecting the ground  water and surface water are VOCs including benzene, toluene, and xylenes.

      The selected remedial action for  this  site includes:  construction of a cap on the landfill  with runoff
directed to appropriate storm or sanitary sewers, and installation of a gas extraction system and gas probes
to monitor methane gas production; installation of a ground water pump and treatment system with discharge
of treated water to  a local creek or  the POTW  and  alternate water supply if needed;  and ground water and
surface water monitoring.  The estimated present worth  cost for this remedial action is between  $21,015,000
and $23,418,000.  The estimated O&M costs were not provided.

PERFORMANCE STANDARD OR GOALS:  Ground water cleanup levels were provided for 10 contaminants
of concern based on MCLs, WQC, pretreatment standards, or risk assessments.   Individual goals include
benzene 5 ug/1 (MCL), toluene 14 ug/1 (WQC), and xylene 10  ug/1 (EPA Risk Assessment).

INSTITUTIONAL CONTROLS:   Deed restrictions will be implemented to restrict  construction of water
supply wells in the affected area.
                                               B-151

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                FRONTIER HARD CHROME, WA
                                       First Remedial Action
                                        December 30, 1987
ROD ABSTRACT
      The Frontier Hard Chrome (FHC) site covering approximately one-half acre, is located in the City of
Vancouver, Washington.  Underlying ground water  is used as the drinking water  supply for the City of
Vancouver.  Two well fields are within one mile of the FHC site.  The site has primarily been occupied by
two businesses engaged in the chrome plating industry. Pioneer Plating operated at the site from 1958 to
1970.   The site  was then occupied by  FHC until  1983.   During Pioneer's operation and FHC's initial
operation, chromium plating wastes were discharged to the sanitary  sewer system.  In  1975, the City of
Vancouver determined that chromium in FHC's waste water was upsetting the operation of its new secondary
treatment system.  FHC was directed by Vancouver  and the Washington Department of Ecology (Ecology)
to cease discharge to the sewer system until a treatment system  was installed to remove chromium from their
waste.  At that time, FHC began discharge of their untreated plating wastes to  a drywell behind the facility.
In 1976, FHC was given a waste water disposal permit for  discharge to the drywell by Ecology.  The permit
also contained a schedule for completion of a  treatment system for their wastes.  In 1982, Ecology found FHC
in violation  of the Dangerous  Waste Act for the  illegal disposal for  hazardous wastes.  In  1983, Ecology
ordered FHC to stop discharge of chromium plating wastes to the drywell.  Ecology discovered chromium
in the ground water at more than twice the drinking water standards, and in soil and FHC building structures.

      The selected remedial action for this site includes: excavation of 7,400 yd  of chromium contaminated
soils exceeding 550 mg/kg, with on-site treatment using chemical stabilization followed by on-site disposal of
treatment residuals and placement of a final site  cover; and demolition of the FHC building. The estimated
present worth cost for this remedial action is $2,000,000.

PERFORMANCE STANDARDS  OR GOALS: Currently,  there are no standards for chromium in the soil.
The site-specific  determination made at the FHC site was to treat soils in excess of 550 mg/kg chromium.
This determination was made relative to the drinking water standard which would be applicable in the future
cleanup of ground  water beneath the site.

INSTITUTIONAL  CONTROLS:  Not applicable.
                                               B-152

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                FRONTIER HARD CHROME, WA
                                   Second Remedial Action - Final
                                            July 5, 1988
ROD ABSTRACT
      The Frontier Hard Chrome (FHC) site, covering approximately one-half acre, is located in the City
of Vancouver, Washington.  The  areal ground water is used as the drinking water supply for the City of
Vancouver, which has two well fields within one mile of the site.  Since 1955, the site has primarily been
occupied by two companies engaged in the chrome plating business. Pioneer Plating operated at the site from
1958 to 1970. The site was then occupied by FHC until 1983.  Presently, the facility is being used  as a
storage and staging area for a neighboring business.  During the operation of Pioneer and the initial operation
of FHC, chromium plating wastes were discharged to the  sanitary sewer system.  In 1975,  the  City of
Vancouver determined that the chromium in the wastewater from FHC was upsetting the operation of its new
secondary treatment system.  FHC was directed by the City and the Washington  Department of Ecology
(Ecology) to  cease discharge to  the sewer system  until a treatment  system  was installed  to  remove the
chromium waste.  At that time, FHC began discharge of their untreated  plating wastes to a dry well behind
the facility. In 1976, Ecology permitted  FHC to discharge to the dry well. Additionally, the permit contained
a schedule for completion of a  waste treatment system. Between 1976 and 1981, several extensions of the
permit and schedule were granted, as the deadlines passed without compliance.  In 1982, Ecology found FHC
in violation of the Washington  State Dangerous  Waste Act for the illegal disposal of hazardous wastes, and
in 1983 ordered FHC to stop discharging to the dry well. As a result, FHC also was required to prepare a
plan for the investigation of the ground water.  FHC closed  down all operations at the site.  The company
did not undertake the investigation. In December 1987, EPA published a ROD for the site's first operable
unit, which addressed the soil  contamination.  This second  and final operable unit  addresses chromium
contaminated ground water.

      The selected remedial action for this site  includes:  ground water pump and treatment using selective
media ion exchange to remove chromium, followed by carbon adsorption to remove VOCs with discharge into
the river or the city sanitary sewer; ground water monitoring; and implementation of institutional controls to
restrict ground water  usage and  to control new well  drilling.  The estimated present worth cost for this
remedy is $3,800,000.

PERFORMANCE STANDARDS OR GOALS:  The selected remedy prevents public exposure to drinking
water that exceeds MCLs for hexavalent chromium 0.05 mg/1, TCE 0.005 mg/1, and  1,1,1-trichloroethane 0.2
mg/1.  Additionally, treated ground water will meet  NPDES  requirements, EPA Water Quality Criteria for
protection  of freshwater aquatic  life,  or  city pretreatment  requirements (depending on  remedial  action
determinations for discharge).

INSTITUTIONAL CONTROLS:  The use of ground water in and around the contaminated  plume will be
restricted.  These restrictions will  be designed to last until chromium levels reach drinking water standards.
                                               B-153

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                            GOULD, OR
                                        First Remedial Action
                                           March 31, 1988
ROD ABSTRACT
      The Gould site is located in a heavily industrial area of Portland, Oregon,  approximately 1.3 miles
southeast of St. John's Bridge. The site is contained in a 60-acre study area consisting of the Gould property
and outlying areas containing battery casings and other residues from site operations.  The area is  sparsely
populated and lies on the left bank floodplain of the Willamette River. Doane Lake, a small pond, is located
adjacent to  the site.  The  Gould site is mostly  paved with asphalt, therefore, on-site flora and fauna are
limited.  Between 1949 and 1981, various  owners  operated  the site as a secondary lead smelting facility
specializing in lead-acid battery recycling, lead-smelting and refining, zinc alloying and casting, cable sweating,
and lead oxide production.  Operations ceased in August 1981; by the summer of 1982, most of the structures,
facilities, and equipment were removed.   Remedial investigation and production records estimate that 86,900
tons of battery casings, 11,800 tons of  matte, and  6,570,000 gallons of acid were  disposed of  at the site.
Approximately 2% of the total volume of battery casings is located in surface piles, the remaining 98% is used
as fill material, and is in direct contact with ground water.  The primary contaminants of concern affecting
the soil and sediments are lead and lead oxide.  VOCs  were discovered in ground water, but will be addressed
in a future operable unit.

       The selected remedial action for  the soils unit at the site include:  excavation of all battery casing
fragments and matte from the Gould property and adjacent contaminated areas; a phased design program to
determine the amount of material that can be recycled, and to minimize the amount of material that  must
be RCRA landfilled;  separation  of battery casing fragments; recycling of all applicable components; off-site
disposal of nonrecyclable material failing the EP Toxicity test; on-site disposal of nonhazardous, nonrecyclable
components; excavation, fixation/stabilization, and on-site disposal of remaining contaminated soil, sediments,
and matte with soil capping and revegetation; isolation of surface water runoff to East Doane Lake by site
regrading; and a monitoring program to determine changes in ground water contamination over time and to
ensure that  remediation does not adversely impact air quality.  Additional ground and surface water studies
will be  performed to determine  the need for remediation of the media. The estimated  capital  cost of this
remedy is $3,491,603, assuming a "worst case" scenario where little of the material is recyclable, with present
worth O&M of $17,073,581.

PERFORMANCE STANDARDS OR GOALS:  Surface soils having a total lead  content above 1000 mg/kg,
and subsurface soils, matte, and  East Doane Lake sediments  failing the  EP Toxicity test, will be fixated and
disposed of on-site.  Site boundaries will be monitored to determine if  lead exceeds the  NAAQs of
1.5 ug/m3.

INSTITUTIONAL CONTROLS:   The  remedy  will incorporate institutional  controls;  however, individual
controls were not specified.
                                                B-154

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                     Progress Toward Implementing Superfund: Fiscal Year 1988
                                     MARTIN MARIETTA, OR
                                    First Remedial Action - Final
                                         September 29, 1988
ROD ABSTRACT
      The 350-acre Martin Marietta Reduction Facility (MMRF) site is located in The Dalles, Wasco County,
Oregon.  The site lies within an 800-acre area used primarily for heavy industry and manufacturing; land not
used for industrial processes is leased for agricultural purposes.   Less  than  20  homes  and businesses are
located in the area of the site. Ground water is an important source of water supply in The Dalles area for
domestic, industrial,  and agricultural uses, and flows in  an easterly direction toward the Columbia  River.
From 1958 to 1970, Harvey Aluminum, Inc., operated a processing facility designed to produce about  90,000
tons of aluminum a year.  Martin Marietta Corporation (MMC) acquired the facility in  1970 and  continued
aluminum processing operations until 1984, when the plant  was shut down.  In 1986, MMC leased the plant
and adjacent portions of the property to Northwest Aluminum Company, which resumed aluminum operations
in 1987.  The MMRF site consists of 28 areas of significant contamination resulting from treatment, storage,
and disposal practices at the site. A 15-acre landfill located near  the aluminum reduction building contains
approximately 200,000  yd   of  waste and plant construction debris.  Leachate emanating from the landfill
operations prior to the installation of a leachate collection  system has resulted in the contamination  of the
area aquifer.  Significant waste types in the landfill include asbestos, metallic wastes, and 5,000 tons of spent
cathode waste materials containing  cyanide, PAHs, and arsenic.  In addition to the landfill, approximately
64,670 yd of cathode waste material was deposited in areas referred to as the unloading area and the cathode
waste management areas scrubber sludge ponds,  consisting  of four surface impoundments, two of which are
covered with soil and vegetation,  cover 14.8 acres, and contain contaminated sludge and subsoil.  The primary
contaminants of concern affecting the soil, ground water,  and debris  are  VOCs including TCE, organics
including PAHs, inorganics including asbestos and cyanide,  and metals including  arsenic.

      The selected remedial  action for this site includes:   excavation of the cathode waste material and
placement into the existing landfill, and covering the landfill with a  RCRA cap; placement of a soil cover over
scrubber sludge ponds 2 and 3; plugging and abandonment of nearby production wells and connecting ground
water users to the City of Dalles water supply system; collection and on-site treatment of leachate generated
from the landfill, the perched  water east of River Road and the cathode waste management areas, and the
ground water in the unloading area using an aqueous treatment system with on-site discharge to a recycling
pond; ground water monitoring; establishment of a contingency plan to perform additional recovery of ground
water in the  event  further contamination  is detected; and implementation of  institutional controls.  The
estimated present worth cost for this remedial action is  $6,707,400 with annual O&M of $144,000 for years
1-5 and $55,600 for years 6-30.

PERFORMANCE STANDARDS OR GOALS:  Cleanup goals based on human health risks and the potential
for contaminants leaching to ground water will be attained for soil and include arsenic 65 mg/kg (carcinogenic
risk) and PAHs 175 mg/kg (urban background).  Ground water ACLs including fluoride 9.7 mg/1 and sulfate
3,020 mg/1 were selected for portions of the aquifer where concentrations exceed the State of Oregon MCLs.

INSTITUTIONAL  CONTROLS:  Deed and well use restrictions will  be implemented during  and after
remediation.
                                                B-155

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                     Progress Toward Implementing Superfund:  Fiscal Year 1988
                                    PACIFIC HIDE & FUR, ID
                                    First Remedial Action - Final
                                           June 28, 1988
ROD ABSTRACT
      The Pacific Hide & Fur (PHF) site consists of approximately 11-acres of fenced land and is located
in the northwest  edge of Pocatello, Bannock County, Idaho.  The  site, a former gravel mining area,  was
purchased by McCarty's, Inc., (MI), a  scrap  metal  dealer, in  1958.  MI purchased scrap metal,  batteries,
drained  transformers, and capacitors filled with  PCB oils from various sources, storing them on-site in a
previously excavated gravel pit. The waste is stored in the excavated pit, comprised of approximately three
acres, for resale, reuse, or salvage.  In August  1979, PHF purchased the rights to salvage scrap metal for four
years.  In the course of salvage operations, materials may have been moved from the pit.  Also, PHF may
have purchased scrap metals  and transformers and stored them on-site. Records indicate  that none of the
new transformers purchased by PHF contained PCB oils.  Transformers containing fluids were drained into
site drums or into the pit. In January 1983, the U.S. EPA and the Idaho Department of Health and Welfare
(IDHW) began investigating the site to  determine whether disposal of PCB oils were occurring on or  off-
site due to operations at the metal facility.  EPA declared the site to  be  an immediate threat to public health
and welfare.  As  a  result, approximately 593 PCB capacitors were transported off-site for  incineration,  and
21 hazardous materials drums and 30 cubic yards of  soil were transported off-site for disposal. Additionally,
11 ground water wells and a security fence were installed at the site. The primary contaminants of concern
affecting the soil  are PCBs.

      The selected remedial action for this site includes: excavation  of soil to an average of 1.5 feet followed
by screening to separate  large contaminated materials and testing for further contamination; stabilization of
a portion of the soil using an  immobilization technique; construction  of a bottom clay liner,  where necessary;
capping of the stabilized  and  remaining  materials; removal of some  ground water monitoring wells; ground
water monitoring; and deed and access.restrictions.  If the fixation technology is found to  be impracticable,
on-site containment will be implemented as the final remedial action.  The estimated present value of this
remedial action ranges from $1,330,000 to $1,890,000.  There is no O&M associated with this remedy.

PERFORMANCE STANDARDS OR GOALS:  The  soil cleanup goal for PCBs of 25 mg/kg by weight  was
established as the EPA cleanup policy for PCB spills, and corresponds with  a 10"  to 10"  health-based  risk
level for the entire  site (including hot spot areas).

INSTITUTIONAL CONTROLS:   Deed restrictions to prohibit  excavation or drilling will be developed
consistent with  final design determinations.
                                                B-156

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988


     Progress toward  implementing Superfund is reflected in Federal Register
notices of the Superfund program actions taken during  the  fiscal year.   During
FY88,  the  Superfund program  published 107 notices  of action  in  the Federal
Register.  The actions that the Agency took resulted in its publishing notices
of proposed and  final  rules,  guidance  documents,  requests for public comment,
and proposed consent decrees  issued by the Department of Justice.  The following
table provides the date,  citation,  action,  and  subject  of  each of these Federal
Register notices.  Where appropriate, it also provides the statutory authority
for the action listed.  Unless otherwise noted, the statute cited  is CERCLA.
                                      C-l

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            Progress Toward Implementing Superfund:  Fiscal Year 1988
                             APPENDIX C

      FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                         TAKEN IN FISCAL 1988
                              (continued)
 Date
Citation/Action
      Subject
OCT 15
1987
OCT 21
OCT 26
NOV 12
NOV 19
NOV 23
52 FR 38340
(Request for comment)
52 FR 39386
(Request for comment)
(§123).
52 FR 40844
(Semi-annual revision of
 regulatory agenda).
52 FR 43393
(Publication of draft
 language)
(§122(g)(4)).

52 FR 44481
(Request for comment)
(§122(d)(3), (h), (i))
52 FR 44938
(Request for comment)
(§107(a)).
Availability of draft
toxicological profiles for 25
of the 100 chemicals that EPA
and ATSDR have determined can
be found at NPL sites and may
pose the most significant
threats to human health.

Interim final rule providing
for reimbursement of local
governments for costs
incurred in responding to
releases or threatened
releases of hazardous
substances.

Schedule for CERCLA
regulations that EPA is
developing, revising, and
reviewing.

Language for drafting de
minimis waste contributor
administrative order on
consent and consent decrees.

Proposed administrative
settlement for cost recovery
action at the Union Chemical
Co.,  Inc.  site in South Hope,
Maine.

Department of Justice (DOJ)
proposed consent decree for
cost recovery action at the
Shenango River Project site
in Vernon, Ohio.
                                 C-3

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                Progress Toward Implementing Supert'und: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                             TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subj ect
7.    DEC 8
8.   JAN 13
     1988
9.   JAN 14
10.  JAN 21
11.   FEE
12.  FEB 10
52 FR 46538
(Request for comment)
53 FR 850
(Proposed rule)
<§120(h)).
53 FR 959
(Request for comment)
53 FR 1641
(Extension of comment
 period).

53 FR 3644
(Request for comment)
(§106(a».
53 FR 3948
(Request for comment)
(§122(d)(2)).
DOJ proposed consent decree
requiring the cleanup and
maintenance of remedy at the
McAdoo Associates site in
McAdoo Borough, Pennsylvania.

Form and manner of contracts
notice required in trans-
ferring Federal real property
on which any hazardous
substance has been stored,
released, or disposed.

DOJ proposed consent decree
for partial cost recovery
action at the SCRDI Bluff
Road site in Columbia, South
Carolina.

Proposed rule for remedial
actions at inactive uranium
processing sites.

DOJ proposed consent decree
resolving action to compel
funding and implementation of
remedial action at the Johns-
Manville Corp. site in
Waukegan, Illinois.

DOJ proposed consent decree
for cost recovery action and
claims for injunctive relief
at the Picillo Farm site in
Coventry, Rhode Island.
                                      C-4

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
13.   FEE 11
14.  FEE 11
15.   FEE 12
16.   FEE 23
17.   MAR 2
53 FR 4070
(Request for comment)
(§§107, 122(g),
53 FR 4085
(Request for
 comment).
(§122(d)(2)).
53 FR 4280
(Initial docket listing)
(§120).

53 FR 5298
(Request for comment)
<§§104(a), 122(a),
 122(e)).

53 FR 6712
(Request for comment)
(§107).
Proposed de minimis
settlement for several sites
in Region 1:   the Plymouth
Harbor/Cannon Engineering
Corp. (CEC) site in Plymouth,
Massachusetts; the Tinkhams
Garage site in Londonderry,
New Hampshire; and the Gilson
Road site in Nashua, New
Hampshire.

DOJ proposed consent decree
determining responsibility
for cost recovery action at
the Rocky Mountain Arsenal in
Adams County, Colorado.

Initial listing of facilities
on Federal Agency Hazardous
Waste Compliance Docket.

Interim guidance on notice
letters, negotiations, and
information exchange.
DOJ proposed consent decree
for cost recovery action and
implementation of remedial
action at the Tysons Dump
site in Upper Merion
Township, Pennsylvania.
                                      C-5

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
18.   MAR 2
19.  MAR 9
20. MAR 14
21.  MAR 14
22.  MAR 17
53 FR 6762
(Request for comment)
(§§102(a), 102(b),
 103(a), 104(b)
 101(14)).
53 FR 7582
(Request for comment)
53 FR 8223
(Request for comment)
(§105).
53 FR 8279
(Request for comment)
(§122).

53 FR 8814
(Request for comment)
Proposed adjustment rule for
one of the two remaining
CERCLA hazardous substances
without a proposed or final
adjusted reportable quantity
(RQ),  lead metal.  Proposed
readjustment of RQs for four
lead compounds.  Proposed
delisting of one CERCLA
hazardous substance.
Proposed replacement of the
trademark "Kelthane" with its
generic equivalent.

DOJ proposed consent decree
for partial cost recovery
action and implementation of
first phase of remedial
action at the Sand, Gravel, &
Stone site in  Elkton,
Maryland.

Proposed rule for deleting
two sites from the NPL: the
Varsol Spill site in Miami,
Florida and the Tri-City Oil
Conservationist, Inc. site in
Tampa, Florida.

Guidance that evaluates three
types of mixed funding
settlements.under CERCLA.

DOJ proposed consent decree
for cost recovery action at
the Harvey & Knott Drum, Inc.
site in Kirkwood, Delaware.
                                      C-6

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                    (continued)
      Date
Citation/Action
      Subject
23.  MAR 17
53 FR 8816
(Request for comment)
24.  MAR 24
25.  MAR 24
53 FR 9700
(Request for comment)
(§122(h), 
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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
28.   MAR 25
29.  MAR 25
30.  MAR 28
31.  APR 1
32.  APR 11
33.  APR 11
53 FR 9807
(Request for comment)
53 FR 9823
(Request for comment)
(§§106(b), 107).
53 FR 9993
(Request for comment)
(§§106, 107).
53 FR 10560
(Request for comment)
(§122(h)).
53 FR 11889
(Extension of comment
 period).

53 FR 11890
(Supplement to proposed
 rule)
(§102(a)).
Proposed administrative
settlement for costs incurred
in removal action at the CSI
Technologies site in
Escondido, California.

DOJ proposed consent decree
addressing alleged PRP
violations of an
administrative order at the
Scientific Chemical
Processing Site in Carlstadt,
New Jersey.

DOJ proposed consent decree
for cost recovery action at
the Mid-South Wood Products
site in Mena, Arkansas.

Proposed administrative
settlement for recovery of
costs incurred in removal
action at the Woodward
Property site in Myrtle
Beach, South Carolina.

Proposed rule on CERCLA
hazardous substance RQ
adjustments.

New information/RQ
adjustments for some CERCLA
hazardous substances
originally proposed on March
16, 1987.
                                      C-8

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subj ect
34.  APR 13
35.  APR 13
36.  APR 13
37.  APR 15
38.  APR 18
39.   APR 19
53 FR 12201
(Request for comment)
(§§104, 107).
53 FR 12201
(Request for comment)
53 FR 12201
(Request for comment)
(§122(d)(2».
53 FR 12613
(Request for comment)
53 FR 12680
(Final rule)
(§105).
53 FR 12868
(Request for comment)
(§§102,  103).
DOJ proposed consent  decree
for cost recovery  action  at
various sites in Cook and Lee
Counties, Illinois.

DOJ proposed consent  decree
for cost recovery  action  and
implementation of  cleanup at
the Chisman Creek  site  in
York County, Virginia.

DOJ proposed consent  decree
for cost recovery  action  at
the Carolawn, Inc. site in
fort Lawn, South Carolina.

DOJ proposed consent  decree
for cost recovery  action  at
the Bayou Sorrel Site  in
Bayou Sorrel, Louisiana.

Deletion of three  sites from
the NPL: the Middletown Road
Dump site in Annapolis,
Maryland; the Harris  (Farley
Street) site in Houston,
Texas;  and the Mountain View
Mobile Home site in Globe,
Arizona.

Proposed rule for  reduced
reporting for continuous
releases of hazardous
substances.
                                      C-9

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
40.  APR 25
41.  APR 26
42.  APR 27
43.  APR 27
44.  APR 28
53 FR 14334
(Semi-annual revision
 of regulatory agenda)
53 FR 14862
(Request for comment)
(§§106, 107).
53 FR 15129
(Request for comment)
(§122(h), (i».
53 FR 15129
(Request for comment)
(§122(h), (i)).
53 FR 15299
(Request for comment)
(§107).
Schedule for CERC1A
regulations that EPA is
developing, revising, and
reviewing.

DOJ proposed consent decree
for cost recovery action at
the Anaconda Co. Smelter site
in Anaconda, Montana
requiring site stabilization
and funding of permanent
relocation of the residents
of Mill Creek, Montana.

Proposed administrative
settlement for recovery of
removal action costs from 58
PRPs at the Bourdeaudhui site
in Willington, Connecticut
and the Kapinos site in
Willington, Connecticut.

Proposed administrative
settlement for recovery of
removal action costs from 10
PRPs at the Bourdeaudhui site
in Willington, Connecticut
and the Kapinos site in
Willington, Connecticut.

DOJ proposed consent decree
for costs  incurred  in  removal
action at  the George 0'Bryan
Site in Louisville, Kentucky.
                                      C-10

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                Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
45.  MAY 5
53 FR 16086
(Request for comment)
(§109(c),(d)).
46.  MAY 13
53 FR 17120
(Request for comment)
47.  MAY 16
53 FR 17228
(Request for comment)
(§105; 40 CFR
 §300.66(c)(8)).
48.  MAY 19
53 FR 17987
(Request for comment)
Interim final rule on
eligibility and procedures
for granting and receiving
awards of up to $10,000 for
information leading to
successful prosecution for
the criminal violation of
CERCLA.

DOJ proposed consent decree
for cost recovery and funding
of remedial action at the
Price Landfill site in
Pleasantville,  New Jersey.

Proposed rule for deleting
three sites from the NPL:
the Gallaway Pits site in
Gallaway, Tennessee; the
Lee's Lane Landfill site in
Louisville, Kentucky; and the
Newport Dump in Newport,
Kentucky.

DOJ proposed consent decree
for cost recovery action at
the McKin Co. site in Gray,
Maine.
49.  MAY 25
53 FR 18913
(Request for comment)
DOJ proposed consent decree
for recovery of removal
action costs incurred at the
Waste Disposal, Inc. site in
Santa Fe Springs, California.
                                     C-ll

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                             TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
50.   MAY 31
51.  JUNE 2
52.  JUNE 2
53 FR 19805
(Reopening of comment
 period).
53 FR 20162
(Request for comment)
53 FR 20165
(Request for comment)
(§§107, 122(g), 122(1))
53.  JUNE 10
53 FR 21929
(Request for comment).
Reopening of comment period
for March 24, 1988 interim
final rule on Technical
Assistance Grants in response
to requests from the public.

Description of the Integrated
Risk Information System
(IRIS), which contains
summaries of some Superfund
regulations, such as the
rules pertaining to RQs.

Proposed de minimis
settlement identical to the
agreement published on
February 11, 1988.  Settling
parties were unable to
participate in the first
settlement for administrative
reasons.

DOJ proposed consent decree
for recovery of removal costs
incurred at 89 compressor
station sites along a gas
pipeline.  The sites are
located in Alabama, Arkansas,
Illinois, Indiana, Kentucky,
Louisiana, Maryland,
Mississippi, Missouri, New
Jersey, Ohio, Pennsylvania,
Tennessee, and Texas.
                                      C-12

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
              Citation/Action
                                    Subject
54.  JUNE 14
55.  JUNE 16
56,
JUNE 23
57.  JUNE 24
58.  JUNE 24
              53 FR 22222
              (Request for comment)
              (§122(d)(3),
              53 FR 22566
              (Request for comment)
              (§§107,
53 FR 23661
(Request for comment)
(§12200).
              53 FR 23978
              (Request for comment)
              (§105).
              53 FR 23988
              (Request for comment)
              (§105).
Proposed administrative
settlement for recovery of
remedial investigation (RI)
costs and requiring
implementation of feasibility
study (FS) work at the Dover
Municipal Landfill in Dover,
New Hampshire.

DOJ proposed administrative
settlement for recovery of
removal costs incurred at the
United Rigging and Hauling
site in Beltsville, Maryland.

Proposed administrative
settlement for recovery of
costs incurred in removal
action at the Southern Lumber
site in Crosby, Mississippi.

Proposed rule to add 13 sites
previously proposed for the
NPL and delete 30 sites from
the NPL.  All 43 sites are
subject to corrective action
authority under RCRA
Subtitle C.

Update #7 of the NPL, which
proposes to add 229 new
sites, expand one final site,
and repropose four sites.
                                      C-13

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                             TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
59.   JUNE 27
60.   JUNE 29
53 FR 24141
(Request for comment)
53 FR 24496
(Request for comment)
(§122(h)).
Availability of two external
review drafts, a cancer risk-
specific dose estimate
document and a document
estimating exposure.

Proposed administrative
settlement for recovery of
costs incurred in removal
action at the Buckhorn
Pesticide site in Buckhorn,
North Carolina.
61.  JULY 5
62.  JULY 7
63.  JULY 11
64.  JULY 14
53 FR 25218
(Request for comment)
(§§106, 107).
53 FR 25537
(Formation of
 discussion group).
53 FR 26090
(Request for comment)
(§105).
53 FR 26660
(Meeting announcement)
DOJ proposed partial consent
decree for cost recovery
action at the A&F Material
Reclaiming, Inc. site in
Greenup,  Illinois.

Availability of minutes from
the first meeting of the
Municipal Settlement
Discussion Group, which
addresses how municipalities
should fit into the Superfund
settlement process.

Proposed rule for deleting
from the  NPL the A.L. Taylor
(Valley of Drums) site in
Brooks, Kentucky.

Municipal Settlement
Discussion Group meeting on
August 4, 1988.
                                     C-14

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
65.  JULY 15
66.  JULY 15
67.  JULY 19
68.  JULY 20
69.  JULY 20
70.  JULY 20
53 FR 26858
(Request for comment)
(§122(h)).
53 FR 26859
(Request for comment)
(§122(h)).
53 FR 27268
(Request for comment)
(§§101, 102, 103, 107,
 109) .

53 FR 27371
(Request for comment)
(§105).
53 FR 27393
(Request for comment)
(§122(h)).
53 FR 27411
(Request for comment)
(§§104, 106).
Proposed administrative
settlement for recovery of
costs incurred in removal
action at the A.Y. McDonald
Industries, Inc. site in
Dubuque, Iowa.

Proposed administrative
settlement for recovery of
costs incurred in removal
action at the Babb Drum site
in Little Chicago, South
Carolina.

Clarification of the
Federally permitted release
exemption from reporting and
liability provisions.

Proposed rule for deleting
from the NPL the Matthews
Electroplating site in
Roanoke County, Virginia.

Proposed administrative
settlement for recovery of
costs incurred in removal
action at the Salvo Property
site in Lithia Springs,
Georgia.

DOJ proposed consent decree
for failure to provide access
to an authorized represent-
ative of the United States to
the Arkwood,  Inc. site in
Omaha,  Arkansas.
                                     C-15

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
71.  JULY 22
72.  JULY 27
73.  JULY 28
74.  JULY 28
75.  AUG 4
76.  AUG 5
53 FR 27679
(Proposed rule)
53 FR 28278
(Request for comment)
(§122(1)).
53 FR 28414
(Request for comment)
(§105).

53 FR 28456
(Request for comment)
53 FR 29428
(Proposed rule)
(§§107(a), 122(h)).
53 FR 29484
(Request for comment)
(NCP §300.66(c)).
Provisions for Occupational
Safety and Health
Administration enforcement of
the Hazard Communication
Standard (HCS).

DOJ proposed consent decree
requiring the implementation
of interim remedial action,
cost recovery action, and the
performance of RI/FS at the
Saltville Waste Disposal
Ponds site in Saltville,
Virginia.

Proposed rule for deleting
from the NPL the Presque Isle
site in Erie, Pennsylvania.

DOJ proposed consent decree
requiring the implementation
of the selected remedy at the
Gold Coast Oil Corp. site in
Miami, Florida.

Procedures for use of
arbitration to settle cost
recovery claims in cases in
which the total response
costs for a site do not
exceed $500,000.

Proposed rule for deleting
the Mowbray Engineering Co.
site in Greenville, Alabama
from the NPL.
                                      C-16

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
              Citation/Action
                                    Subject
77.  AUG 8
78.  AUG 8
79.  AUG 8
80.  AUG 9
81.
AUG 9
82
AUG 9
              53 FR 29789
              (Request for comment)
              (§107).
              53 FR 29789
              (Request for comment)
              (§§107, 122{g)).
              53 FR 29790
              (Request for comment)
              (§107).
              53 FR 29959
              (Request for comment)
53 FR 30002
(Request for comment)
(§§101(23), 101(24),
 105(a)(8)(A),
 105(a)(8)(B)).
53 FR 30005
(Policy statement)
(§§101(23), 101(24)
 105(a)(8)(A),
 105(a)(8)(B)).
Three DOJ proposed consent
decrees for cost recovery
action at the Goose Farm site
in Plumstead Township, New
Jersey.

DOJ proposed consent decree
for costs incurred and to be
incurred at the Lipari
Landfill in Pitman, New
Jersey.

DOJ proposed consent decree
for costs incurred in removal
action at the Bliss/Frontenac
site in Frontenac,  Missouri.

Two DOJ proposed partial
consent decrees for the four
sites originally proposed for
administrative settlement on
February 11, 1988.

Proposed policy statement on
criteria for determining
inability of RCRA-regulated
site owner/operators to
finance cleanups, thus
allowing some RCRA sites to
be proposed for the NPL.

Policy statement on criteria
for determining unwillingness
of RCRA-regulated site owner/
operators to finance clean-
ups, thus allowing some RCRA
sites to be proposed for the
NPL.
                                     C-17

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
83.   AUG 10
84.  AUG 12
85.  AUG 18
53 FR 30120
(Request for comment)
53 FR 30452
(Request for comment)
(§105).
53 FR 31402
(Request for comment)
86.  AUG 18
53 FR 31403
(Request for comment)
87.  AUG 22
53 FR 31871
(Final rule)
(§109(e)).
DOJ proposed consent decree
for cost recovery action at
the City Industries, Inc.
site in Orlando, Florida.

Proposed rule for deleting
from the NPL the Toftdahl
Drums site in Bush Prairie,
Washington.

DOJ proposed stipulation
concerning distribution of
proceeds from the sale or
lease of parts of the
American Creosote Works, Inc.
site in Pensacola, Florida.

DOJ proposed consent decree
to grant access to and not
allow PRPs to interfere with
the remedy selected for the
Taylor Borough Dump site in
Taylor Borough, Pennsylvania.

Procurement procedures for
contracting expert services
in preparing or prosecuting a
civil or criminal action.
                                      C-18

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                             TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
88.   AUG 29
89.  AUG 29
53 FR 32899
(Postponement).
53 FR 32949
(Request for comment)
Postponement of North
Carolina withdrawal proceed-
ings published on June 7,
1988.  EPA suspends the
hearing until further notice,
pending a national policy
review of CERCLA capacity
issues.

DOJ proposed partial consent
decree for cost recovery
action at the Clean Well
Field site in Clean, New
York.
90.  AUG 31
91.   AUG 31
92.  AUG 31
93.   SEPT 1
53 FR 33557
(Request for comment)
(§§106, 107).
53 FR 33558
(Request for comment)
53 FR 33618
(Request for comment)
(§104(c)(9), (k)).
53 FR 33811
(Notice of deletion).
DOJ proposed consent decree
for cost recovery action and
implementation of selected
remedy at the Seymour
Recycling Corp. site in
Seymour, Indiana.

DOJ proposed consent decree
for cost recovery action at
the Times Oil Co. site in
Tacoma, Washington.

Availability of draft
guidance for meeting capacity
assurance requirements and
preparing State Capacity
Assurance Plans (CAPs).

Deletion of two sites
originally proposed for
deletion from the NPL on
March 14, 1988.
                                     C-19

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
94.  SEPT 2
95.  SEPT 7
96.  SEPT 9
53 FR 34173
(Request for comment)
53 FR 34593
(Request for comment)
(§§106,  107).
97.  SEPT 13
53 FR 35110
(Request for comment)
(§122(h)).
53 FR 35373
(Request for comment)
(§12200).
98.  SEPT 13
53 FR 35373
(Request for comment)
(§122(10).
DOJ proposed consent decree
for cost recovery action and
implementation of the
selected remedy at the
Celanese Corp. (Shelby Fiber
Operations) site in Shelby,
North Carolina.

DOJ proposed consent decree
for cost recovery action and
implementation of the
selected remedy at the Brown
Wood Preserving site in Live
Oak, Florida.

Proposed administrative
settlement for costs incurred
in removal action at the Rome
Coal Tar site in Rome,
Georgia.

Proposed administrative
settlement for costs incurred
in removal action at the
Clayton Ballfield Pesticide
site in Clayton, North
Carolina.

Proposed administrative
settlement for costs incurred
in removal action at the Rock
Road Drums Spill site in
Greenville, South Carolina.
                                      C-20

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
99.  SEPT 13
100. SEPT 20
101. SEPT 20
102. SEPT 21
103. SEPT 22
53 FR 35412
(Final rule)
(§§101(14), 102(b),
 103(a)).
53 FR 36489
(Correction).
53 FR 36489
(Request for comment)
(§122(h)).
53 FR 36661
(Request for comment)
53 FR 36869
(Request for comment)
(§105(e),   40 CFR
 §300.66(c)(7)).
Amendments to 40 CFR 302,
which designates six wastes
as CERCLA hazardous
substances and establishes
RQs applicable to those
wastes.

Correction of date of end of
comment period for the
proposed rule for deleting
the Mowbray Engineering Co.
site in Greenville, Alabama
from the NPL.  The proposed
rule was published on
August 5, 1988.

Proposed administrative
settlement for costs incurred
in removal action at the
Bostic Drum site in Holly
Ridge, North Carolina.

DOJ proposed consent decree
for cost recovery action and
implementation of remedial
action at the Litchfield
Airport Area site in
Goodyear/Avondale,  Arizona.

Proposed rule for deleting
the New Castle Steel site in
New Castle County,  Delaware
from the NPL.
                                      C-21

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                Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX C

           FEDERAL REGISTER NOTICES OF SUPERFUND PROGRAM ACTIONS
                              TAKEN IN FISCAL 1988
                                   (continued)
      Date
Citation/Action
      Subject
104. SEPT 23
105. SEPT 23
106. SEPT 26
107. SEPT 27
53 FR 37051
(Request for comment)
<§122(h».
53 FR 37005
(Extension of comment
 period).
53 FR 37344
(Request for comment)
(§12200, (i))-
53 FR 37643
(Request for comment)
(§12200).
Proposed administrative
settlement for costs incurred
in removal action at the
Miller site in Roan Mountain,
Tennessee.

Extension of comment period
for the proposed rule
clarifying Federally
permitted release exemption
from reporting and liability
provisions, which EPA
orginally published on
July 19, 1988.

Proposed administrative
settlement for cost recovery
action at the Boykin and
Ingram Metal Plating Shop
site in San Diego,
California.

Proposed administrative
settlement for costs incurred
in removal action at the
Simpson Road Drum site in
Atlanta, Georgia.
                                      C-22

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                Progress Toward Implementing Superfund: Fiscal Year 1988


                                  APPENDIX D

                SUPERFUND DOCUMENTS ISSUED DURING FISCAL 1988
Document
 Number                           Title                                Date

9200.3-01A  Superfund Comprehensive Accomplishments Plan Manual,    10/01/87
            Fiscal 88

9200.3-04   Resource Distribution for the Technical Assistance      06/29/88
            Grant Program (Memorandum)

9200.3-05   Flexibility in the FY-88 Extramural Operating Plan      06/07/88

9200.7-01   Catalog of Superfund Program Directives                 07/31/88

9230.0-31B  Community Relations in Superfund:  A Handbook (Interim      03/88
            Version)

9230.1-02   Technical Assistance Grants Program Activities Prior    01/11/88
            to Issuance of Final Rule (Memorandum)

9230.1-03   Citizen's Guidance Manual for TAG Grant Program         06/01/88

9230.1-04   Superfund TAG Grants Program Regional Guidance Manual   07/01/88

9230.2-01   OERR Communications Planning Process                    09/15/88

9230.2-02   Peer Review and Approval of Abstracts & Papers          06/26/88

9234.1-01   CERCLA Compliance with Other Laws Manual (Draft         08/08/88
            Guidance Part I)

9234.1-02   Draft CERCLA Compliance with Other Laws Manual
            (Guidance, Part II)                                     07/14/88

9240.0-03   Superfund Analytical Data Review and Oversight          08/18/88

9242.2-01B  ERCS (Emergency Response Cleanup Services) Contracts    10/20/87
            Users'  Manual

9242.5-02   Model Performance Standards for Superfund Project       09/26/88
            Officers, Deputy Project Officers and Work Assignment
            Managers/Delivers Order Officers

                                                                    07/05/88
9285.1-01C  Standard Operating Safety Guides
                                      D-l

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX D
                SUPERFUND DOCUMENTS ISSUED DURING FISCAL 1988
                                   (continued)
Document
 Number                           Title                                Date

9285.4-03   Health Assessments by ATSDR in FY-88                    04/07/88

9320.2-3A   Procedures for Completion and Deletion of National         09/88
            Priorities List Sites (Draft)

9345.0-01   Preliminary Assessment Guidance - FY-88                 02/12/88

9355.0-14   Compendium of Superfund Field Operations Methods        12/01/87

9355.0-23   Interim Guidance on Funding for Ground and Surface      10/26/87
            Water Restoration Activities

9355.0-24   OSWER Strategy for Management Oversight of CERCLA       12/28/87
            Remedial Action Start Mandate

9355.3-01   Guidance for Conducting Remedial Investigations and        03/88
            Feasibility Studies under CERCLA (Draft)

9355.3-02   Guidance on Preparing Superfund Decision Documents:        03/88
            The Proposed Plan and the Record of Decision (Review
            Draft)

9355.3-03   Guidance Document for Providing Alternate Water         02/01/88
            Supplies

9355.3-06   RI/FS Improvements Followup                             04/25/88

9360.0-03B  Superfund Removal Procedures Revision 3                 02/02/88

9360.0-18   Removal Program Priorities                              03/31/88

9360.1-01   Interim Final Guidance on Removal Action Levels at      10/06/87
            Contaminated Drinking Water Sites

9360.2-01   Model Program for Site File Management                  07/18/88

9375.1-04X  State Participation in Superfund Program Manual         05/01/88

9375.1-11   Procurement Under Superfund Remedial Cooperative        06/01/88
            Agreements
                                      D-2

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX D
                SUPERFUND DOCUMENTS ISSUED DURING FISCAL 1988
                                   (continued)
Document
 Number                           Title                                Date

9375.1-12   State Access  to EPA  Contractors During Remedial         04/27/88
            Response

9375.1-13   Clarification on Allowability of Management Assistance  09/21/88
            to States for ERAs and Removals

9375.2-03   Funding for State Core Program Cooperative Agreements   08/21/88
                               OWPE DOCUMENTS

            Interim Guidance on Potentially Responsible Party       05/16/88
            Participation in Remedial  Investigations

            Interim Guidance on Selection  of Remedy                 12/24/87
                                      D-3

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


                                  APPENDIX E

                     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.
                                      E-l

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                 Progress Toward Implementing Superfund: Fiscal Year 1988

                                  APPENDIX E

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

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.


                                     E-2

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988

                                  APPENDIX E

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


     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 (IAGs).*  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 IAGs
and  to  improve accounting  and  cost  documentation  practices.   A draft  manual
entitled Regional  Processing of Superfund IAGs was distributed in July 1987.
     ^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.
                                      E-3

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                Progress Toward Implementing Superfund: Fiscal Year 1988

                                  APPENDIX E

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

     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
MOD 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.
                                      E-4

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                Progress Toward Implementing Superfund: Fiscal Year 1988


                                  APPENDIX F

                        EPA INSPECTOR GENERAL REPORT
                         UNDER CERCLA SECTION 301 (h) (2)

                                   CONTENTS

                                                                           Page

SUMMARY OF RESULTS   	      F-2

SCOPE OF OBJECTIVES    	      F-3

DETAILS OF REVIEW   	      F-5

     Annual Report Chapter 3.0 -- Responses at Sites With
     Hazardous Substances Releases  	      F-5

     Annual Report Chapter 4.0 -- Site Discovery and Assessment .  .   .      F-8

     Annual Report Chapters 3.0 and 4.0 -- Additional Comments  .  .   .      F-9

     Annual Report Chapter 5.0 -- The National Priorities List
     of Sites	     F-10

     Annual Report Chapter 6.0 -- Enforcement Program Activities  .   .     F-ll

     Annual Report Chapter 11.0 -- Technology-Related Research
     and Development	     F-12

     Annual Report Chapter 14.0 -- Executive Branch Estimate of
     Resources Needed to Complete Superfund Implementation  	     F-12

     Annual Report Preparation Process  	     F-12

EXHIBITS

     Exhibit 1	     F-14
                                      F-l

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     r
     1  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
     /                    WASHINGTON. D.C. 20460

                               MAR 2 8 1990
                                                            THE INSPECTOR GENERAL
MEMORANDUM

SUBJECT:  Audit Report No. E1SFF9-11-0015-0100227
          Review of the Fisal Year 1988 Superfund Report to Congress
FROM:                    _
          InspecTp?^t5eneral (A-109)

TO:       Williain*K\ Reilly
          Administrator (A-100)
SUMMARY OF RESULTS

     We have completed our review of the Environmental Protection Agency's (EPA)
report to Congress on Progress Toward Implementing Superfund:  Fiscal Year 1988
(Annual Report).  We  found  that while some sections  of the Annual  Report were
accurate and reasonable, others were not.   Further, the process the Agency used
to prepare  the  Annual  Report  was not timely.   The  problems we identified with
the accuracy and timeliness of this Annual Report were essentially the same as
those we identified for fiscal year 1987 (FY87).  However, due to the length of
time taken to prepare the FY87 Annual Report, EPA was not able to take corrective
action on our FY87  findings in time to affect the  quality of  the  FY88 data or
timeliness of the report.  EPA has now established a work group to improve the
Comprehensive Environmental Response,  Compensation,  and Liability Information
System (CERCLIS) input controls,  and is performing monthly data quality audits.
Further, actions have  been taken to  improve  the process  for  preparing future
Annual Reports  in a more timely manner.

     Some sections  of  the Annual Report,  such as  key information  presented in
Chapter 5.0 on  sites  deleted  from  the National Priorities List (NPL),  Chapter
6.0 on  the  enforcement program,  and  Chapter  11.0 on  the  Superfund Innovative
Technology  Evaluation  (SITE)  Program,  were generally  reasonable and accurate.
However, certain information presented in Chapters 3.0 and 4.0 was not reasonable
or accurate. Significant portions of the accomplishments claimed by the Regions
were not supported  by valid source documents  (see Exhibit  1,  page  F-14),  for
several reasons.  In  some  cases  the source documentation indicated the action
either did  not  meet Agency definitions  or did not occur  in  fiscal year 1988
("invalid actions").   In other instances,  we were unable  to  locate  adequate
supporting  documentation to  determine whether  or when  the  action  occurred
("source documents not located").   Also,  program accomplishments figures in the
Annual Report were  not  always  complete because CERCLIS  is routinely updated
months after the fiscal year end.

     Appendix A does not always show the original estimated completion dates for
Remedial Investigations/Feasibility Studies (RI/FSs) and Remedial Actions (RAs)
in-process at the end of FY87.  While it identifies delays that occurred during
FY88, it does not identify any delays which may have occurred in prior years.


                                      F-3

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     The process used to prepare the FY88 Annual Report was not fully effective,
due to many of the  same  problems that occurred with the FY87 Annual Report.  For
example, the  Annual Report coordinator's  resources  were  limited,  and he had
difficulty obtaining some key end of fiscal year data.  Also, the  tracking system
available  for the  signatory  officials was  not  complete and  accurate,  thus
hindering their monitoring of the  process.  Finally,  the  report  coordinator was
still working on the FY87 Annual Report when this one was past due. As a result,
the FY88 Annual Report was submitted to the  Office of Management and Budget  (OMB)
for review one month later than last year's report.   And  this  Annual Report was
not completed until December 1989, even  though it was due  to Congress in January
1989.

SCOPE AND  OBJECTIVES

     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 began our review on  January 30, 1989,  at EPA Headquarters and in Regions
4 and 5. We completed virtually all of our work by September 28,  1989,  when EPA
sent the Annual Report  to OMB for review.   However, we also reviewed the final
changes made to the Annual Report  in December 1989, after OMB's  review  had been
completed.

     Our work focused on FY88 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  Headquarters and Regions  4  and 5 to
verify the  accuracy of selected key information presented in the following Annual
Report chapters and  related appendices:

     •    3.0:  "Responses at Sites with Hazardous Substance Releases";

     •    4.0:  "Site Discovery and Assessment";

     •    5.0:  "The National Priorities List of Sites";

     •    6.0:  "Enforcement Program Activities";

     •    11.0: "Technology-Related Research and Development";  and

     •    14.0:  "Executive  Branch  Estimate  of  Resources Needed  to   Complete
          Superfund  Implementation".

     As previously stated, some of the information in the Annual Report was not
finalized until  December  1989.   In order  that our  review would not delay the
Annual  Report any  further,  we began  our  field work by  using an October 1988
draft, and used updated drafts as they became available.    We  focused our  field
work on  those items CERCLA  specifically required to  be included in the Annual
Report.  We  performed  detailed  audit  work in Regions 4 and 5 because  of  their
volume of Superfund activity.  Recognizing Regional differences, we hoped in this
manner to obtain a balanced, nationwide perspective in our review.
                                      F-4

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     For the information in Chapters 3.0, 4.0, 5.0, and 6.0, we obtained CERCLIS
printouts  in January 1989, and  matched the nationwide  summary totals to  the
totals  in  the  Annual  Report.   We also selected samples of cases for review in
the pre-remedial, removal,  remedial, and enforcement programs.  We did not secure
the printouts from the CERCLIS  data  base ourselves.  Instead, we relied on  those
provided by  the Office of  Solid Waste and Emergency Response  (OSWER) to define
our universe of cases.

     For our sample cases,  we reviewed the source documentation in Regions  4  and
5 to determine whether the  activities  claimed met the definitions for valid FY88
actions.   The  specific source documentation reviewed varied from activity  to
activity.  For  example, for Preliminary Assessment  (PA) Completions,  the  official
Agency  definition states that "a PA is complete  when the  report is  reviewed  and
accepted by the Region and the  PA completion date  is entered into CERCLIS."   In
accordance with this definition, we  reviewed source documents showing the review
and acceptance of the PA report by the Region,  such as the PA  report  itself  and
Regional logs; we  also  reviewed  the CERCLIS printout showing the entry of  the
action  into  the  data  base.  We performed this  same type of review for  each  of
the pre-remedial, removal,  remedial, and enforcement actions selected for review.
Although virtually every one of our sample  items was selected  at random, we  did
not select a statistically valid sample.  Therefore,  the  results of  our review
should  not be projected throughout  EPA.

     During  our  review  of  the FY87 Annual Report, we  identified  four   PA
Completions and one RI/FS Start in Region 5  that  were claimed in FY87,  but should
have been  counted  in FY88.    Because of this, we reviewed  these  five  cases
specifically to determine whether they were  counted again in the FY88 statistics.

     We reviewed  the  information presented  in  the Agency's report on the SITE
Program.   Concurrent  with our  review of  the  Annual  Report,  the  Office   of
Inspector General (OIG) was conducting a survey  of the SITE Program  to ascertain
whether an audit  was  warranted.   To determine  if  the information presented  on
the SITE Program was reasonable and accurate, we  asked the OIG auditors surveying
the SITE Program to review this chapter.

     We did not perform  in-depth audit  work on  Chapter 14.0,  for two reasons.
First,   most  of it is budget information that is  readily available within  the
Agency.  Second,  section 14.3  was not added to  the report until the July 1989
draft,   after we had completed our field work.

     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
Government Auditing Standards  (1988  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  CERCLA, 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,
nothing came to our attention which warranted more  detailed audit work than that
described in the DETAILS OF REVIEW  section.
                                      F-5

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


DETAILS OF REVIEW

     Annual Report Chapter 3.0 -- Responses at Sites with Hazardous Substance Releases

     Removal Program

     The Annual Report's nationwide and Region 4 and 5 totals for Removal  Starts
and Removal Completions  differed  slightly from those on the CERCLIS printouts
provided to us.   Nationwide Removal Starts totaled 328 in  the Annual Report  and
326 in CERCLIS.  Nationwide Removal Completions totaled 282 in the Annual Report,
but only 277 in CERCLIS.   Region 4 and 5 Removal Starts totaled 96  in the  Annual
Report and  95 in CERCLIS,  while Region 4 and 5 Removal Completions totaled 87
in  the  Annual  Report  and  85  in  CERCLIS.   OSWER officials attributed  these
differences to the  fact that the larger numbers take into account sites with more
than one removal action, whereas the CERCLIS  totals equate  each site with only
one such action.

     Of the 47  Removal  Starts and  11  Removal Completions we reviewed,  51  (88
percent) were valid FY88 actions.   However,  seven of  the actions were not valid
FY88 accomplishments.

     Four of these  seven  actions were not valid because, based on official  Agency
definitions, they should have been recorded in a different  fiscal year.   In fact,
one of these  four  was actually an FY87 Removal Start that was counted in both
FY87 and FY88.

     For the  other three  actions,  the source documentation did  not   show  any
evidence that the Agency definitions  of a  start or  a  completion  were met,
regardless of the fiscal year  involved.  For example,  the Marietta  Mercury Spill
site in Region 4 was counted as both an EPA-lead  first Removal  Start and first
Removal Completion, even though the definition was never entirely  met  in  either
case.   Specifically,  EPA received  notification  of "about a six  ounce mercury
spill" on the floor of a personal  residence in Marietta, Georgia.   The  On-Scene
Coordinator (OSC) first mobilized a contractor to assist in removing the  mercury.
The  OSC then went to  the residence  and was  told  EPA's  assistance  was  not
required.  The resident of the home said that a relative would help in  removing
the mercury.  The  OSC subsequently  stated in  a memorandum to his  file  that  EPA
did not use the contractor to  do any removal actions at the residence.   EPA paid
$1,000 to mobilize the  contractor,  even though the contractor's  services were
not needed.

     OSWER  Directive  9200.3-1A states  that a first  Removal Start occurs when
removal  activity has begun.   Furthermore,  the  directive  states  that a first
Removal Completion is counted  on the day the  on-site removal action is completed.
We  believe that  the Marietta Mercury Spill site  does  not  meet the  Agency
definition  of a Removal Start or a Removal Completion.   In addition, our  review
of CERCLIS  revealed that this site was also counted as a responsible party-lead
subsequent  Removal Start and Removal  Completion,  because the resident  of  the
house stated  she would clean  up the mercury.
                                      F-6

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                Progress Toward Implementing Superfund:  Fiscal Year 1988


     Figure 1 provides the detailed results of our removal program  review.

                                    Figure 1

                              REMOVAL PROGRAM
Removal Starts
Regions:
4 5 Total
Number in the Annual Report 62 34 96
Universe per CERCLIS 62 33 95
Sample Size 29 18 47
Valid FY88 Actions 26 16 42
Source Documents Not 000
Located
Invalid FY88 Actions 325
Removal Completions
Regions:
4 5 Total
55 32 87
55 30 85
7 4 11
639
000

112
     Remedial Program

     Both the Annual Report  and  the  CERCLIS printouts listed 150 RI/FS  Starts
nationwide in FY88.   For the  two  Regions  which we  reviewed,  CERCLIS  reported 42
RI/FS Starts.  We sampled 13  RI/FS Starts and determined that all 13 were valid
FY88 actions.

     We found that the number of Records of Decision (RODs) listed in the  Annual
Report as completed  nationwide  during FY88 was almost identical to CERCLIS.  The
Annual Report listed 152 and CERCLIS listed 154 RODs in FY88.  CERCLIS identified
37 RODs for Regions  4 and 5,  and all 15 RODs we reviewed were valid FY88 actions.

     The  nationwide totals  for   Remedial Design (RD)  Starts   and RA  Starts
contained in the Annual  Report   agreed  with  those  on  the CERCLIS  printouts
provided to us.  Of the  99 RD  Starts during FY88, 28 were  in Regions  4  and 5.
For RA Starts, these Regions accounted for 18  of  the 72  nationwide.

     Of the  15 RD Starts and 15 RA Starts we reviewed, 29  (97 percent) were valid
FY88 actions.  The  one invalid action was due  to  the funds  not being obligated
on an EPA-lead site  as  of the  end of FY88.   The definition  of an RD Start  for
this type of site includes obligating the funds.  Figure 2 provides the detailed
results of our RD and RA Starts review.
                                      F-7

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                 Progress Toward Implementing Snperfund:  Fiscal Year 1988


                                    Figure 2

                 REMEDIAL DESIGN AND REMEDIAL ACTION STARTS

Universe per CERCLIS
Sample Size
Valid FY88 Actions
Source Documents Not
Located
Invalid FY88 Actions
RD Starts
Regions:
4 5
10 18
4 11
4 10
0 0

0 1

Total
28
15
14
0

1
RA Starts
Regions:
4 5
8 10
8 7
8 7
0 0

0 0

Total
18
15
15
0

0
     CERCLA section 301(h)(l)(C)  requires  the Agency to include in  the  Annual
Report  "notice  of each  (feasibility)  study which will  not meet a  previously
published schedule for  completion and the  new estimated date  for completion."
The Annual Report addresses this requirement in Appendix A.  It is important for
the  reader to  understand  that  this appendix  shows  "previously  published"
completion dates  which  were estimated no  earlier  than the beginning  of FY88.
For projects in-process  at that  time, these dates were taken  from  the column,
9/30/87 Est. Completion  included  in  Appendix D of the FY87 Annual Report.   So
for these projects, lengthy delays which may have occurred prior to the beginning
of FY88 are not  shown  (see  Figure  3 for RI/FS examples).  OSWER officials stated
that the  revised estimated dates  of completion contained  in the FY87  Annual
Report constituted a  "previously published schedule,"  so  comparing  these dates
with the new 1988 estimates satisfied the  statutory  intent  of CERCLA.
                                      F-8

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                 Progress Toward. Implementing Superfund: Fiscal Year 1988
                                     Figure 3

                      STATUS OF REMEDIAL INVESTIGATIONS/
                          FEASIBILITY STUDIES ON 9/30/88


Site Name
Kellogg-Deering Well Field
Groveland Wells
New Bedford Site
Per FY87
Annual Report:
"1/1/87 Est.
Completion"
2/88
1/88
2/88
Per FY88
Annual Report:
"Previously Pub.
Completion Sch."
2/89
4/89
2/89
     Annual Report Chapter 4.0 ~ Site Discovery and Assessment

     Pre-Remedial Program

     The nationwide totals  for PAs  and  Site Inspections (Sis) contained in the
Annual Report agreed with those on the CERCLIS printouts provided to us.  Of the
2,884 PAs completed during  FY88,  784 were in Regions 4 and  5.   For Sis,  these
Regions completed 413  of the  1,237  nationwide.

     Of the 44 PA Completions  and 31 SI  Completions we reviewed, 25 (33 percent)
were valid FY88 actions.  Five were not valid FY88 actions;  instead,  according
to official Agency definitions,  they should have been  recorded in a different
fiscal year.  Three of these five were part  of a batch of 74 PA reports actually
input to CERCLIS on November 4, 1988 (FY89), but which were erroneously recorded
as November 4, 1987 (FY88).

     In addition, we were unable  to locate adequate source documentation for 45
(60 percent) of the 75 sample cases.  Specifically,  in Region 4 we located all
of the reports,  but  there was no evidence  on the reports,  such  as  a date and
signature, to show that  they  had been reviewed and accepted  by the  Agency.   A
log was maintained of  approximately 60  percent of the  reports,  but  it did not
show  review and  acceptance.   Further,  some  of  the  reports  themselves  were
undated, and others were very old,  in one case dating  back  to  FY81.   Region 4
officials stated  that  they  did not document  the review and  acceptance  on the
reports because  they entered  the dates  into a computer data  base instead.   In
Region 5,  Regional personnel could not locate  some of the reports.  The Regional
log was sporadically maintained during FY88, and as a result,  in  some cases there
were no  entries for these  reports  documenting  Agency  review  and acceptance.
Figure 4 provides the  detailed results  of our review.
                                      F-9

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


                                    Figure 4

                            PRE-REMEDIAL PROGRAM
PA Completions
Universe per CERCLIS
Sample Size
Valid FY88 Actions
Source Documents Not
Located
Invalid FY88 Actions
Regions:
4 5
170 614
16 28
0 13
16 12

0 3
Total
784
44
13
28

3
SI Completions
Regions:
4 5
182 231
15 16
0 12
15 2

0 2
Total
413
31
12
17

2
     The Annual Report  states  that  the Agency met the January  1,  1988,  CERCLA
target for completing PAs for all sites  in CERCLIS as of October 1986.  However,
the reader should note that the FY87 Annual  Report acknowledged that the Agency
may not  meet  a similar  goal for  Sis.   Part  of the reason  for this may  be a
reduction  in  SI  completion volume  in FY88.  According  to Exhibit  1.0-4,  the
number of FY88 SI Completions was  the lowest in the last  five years,  decreasing
from FY87  levels  by seven percent.   This reduction  in  volume must  have  been
anticipated, because the Agency established  an FY88 target 16 percent lower than
the FY87 accomplishment.  Although  the  Agency apparently exceeded its own FY88
target for SI Completions, this target would not have been sufficient to induce
Agency components to meet the CERCLA  deadline.

     Annual Report Chapters 3.0 and 4.0 -- Additional Comments

     According to OSWER  officials, CERCLIS was expanded and improved during FY88.
However,  as previously  discussed,   our review  identified  concerns with  the
accuracy of some  data in  the system.   Further examples of system problems include
the following:

     •    In  December  1988,  we requested  that  Headquarters  OSWER
          officials provide us  CERCLIS printouts from which to select
          our samples for Regions 4 and 5.   We were initially advised
          that  printouts  could  not  be  provided   due   to  "data
          discrepancies."    During  January  1989,   these  officials
          apparently  believed   the  discrepancies  were  sufficiently
          resolved, and  we received our printouts.
                                      F-10

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


     •    During  our  field work,  Region  5  officials  advised  the
          auditors   that   they   considered  the  system   to  contain
          inaccuracies.

     From our discussions  and observations in the two Regions,  we believe that
inadequate  input  controls continue to  hamper the accuracy and  reliability of
CERCLIS.  OSWER officials advised us that a work group has been formed to review
these input  controls and make recommendations  for improvements.   In addition,
they stated  they  are conducting  monthly data quality audits.

     In  addition  to our  concern  about  the accuracy  of  the  data,  CERCLIS
accomplishments for  FY88  differed depending on the date of the  printout.   For
example, we  obtained three different figures for Removal Starts  in  Region 4.
A  Headquarters  CERCLIS  report  dated October 19, 1988,   listed 62;  the  draft
Annual  Report dated February 23,  1989,  listed 67;  and a  Region 4  CERCLIS
printout dated March 14,  1989, listed 65.

     OSWER Directive 9200.3-lA established a cut-off date of  October 17,  1988,
for producing final  quarter accomplishments reports.   However,  the Regions did
not adhere to the cut-off  date and  continued to input information into  CERCLIS
months  after the end of  the  fiscal 'year.   OSWER  officials  stated that  for
purposes  of completeness,  the  Agency  wants to  get  all accomplishments  into
CERCLIS, regardless  of lateness.   Nevertheless, since the CERCLIS runs used for
the Annual Report were generated shortly after the cut-off  date,  and since the
Regions continued to enter accomplishments into  the  system,  the  Annual  Report
may be understating  some Agency  accomplishments.

     The reader should understand that  in some instances, activities  conducted
at  a  site  are  claimed  in multiple  categories,  i.e.,  both as  Removals  and
Remedial Actions.  These same activities are apparently considered to meet more
than one Agency definition.  For  example,  at the Region 4 Newport Dump site,  the
documentation in  the files stated  that "the remedial action was  initiated on
July 2, 1987 and  completed on October 31,  1987."  Yet the CERCLIS printouts we
received indicated that not one,  but three actions occurred on October 30,  1987:
a Removal Completion;  a  first RA Completion; and a final RA  Completion.   Some
Agency officials have devised the term  "removials" to apply  to these cases;  OIG
auditors in Region 4 have  initiated an  audit of this  practice.

     Following up on our FY87 review,  we found that the four PA  Completions and
one RI/FS  Start  which Region 5  counted in  FY87, but should  have  recorded in
FY88,  were not counted again in  this year's statistics.  However,  based  on the
previously discussed Removal  Start which  Region  5  counted  in both years,  the
potential exists  that other accomplishments may also  be  doubled counted.

     Annual Report Chapter 5.0 - The National Priorities List of Sites

     The Annual  Report listed five sites deleted from  the NPL nationwide  in
FY88.    We obtained  documentation  from Headquarters which verified that  the
Agency deleted these five sites from the NPL.  Two of the sites  deleted were in
Region 4, while  Region 5  did not have  any sites deleted.  We  did not do  any
further work in Region  4 validating the  completion dates for  the two  sites
deleted.
                                      F-ll

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


     Annual Report Chapter 6.0 -- Enforcement Program Activities

     We  reviewed four categories  of enforcement  activities  discussed  in  the
Annual  Report:    Administrative   Orders   (AOs);   RI/FS   Settlements;   RD/RA
Settlements;  and Referrals.   In  most cases,  the nationwide  CERCLIS  totals
provided to  us  agreed with the  totals shown in the  Annual Report.   The  only
instance in which the  nationwide totals did not agree was  in the  AO category.
The CERCLIS  printouts  showed 202  Unilateral/Administrative Orders,  while  the
Annual Report contained 207.

     For our samples of cases selected in each  activity  category,  we were able
to locate all appropriate source documents and verify that the actions occurred
during FY88, as claimed.   Figure  5  outlines the number of sample cases reviewed.

                                     Figure 5

                         ENFORCEMENT CASES REVIEWED
Enforcement Category
Administrative Orders
RI/FS Settlements
RD/RA Settlements
Referrals
Number of Actions
in Regions 4 and 5
60
26
12
31
Sample
Size
7
13
12
6
     The reader should note  that  for  these  settlements,  not all parties to the
settlement have to  be  in agreement,  nor all monies collected,  to  meet the EPA
definition of  an  accomplishment.   For  example,  at the time of  our  review the
Consent Decree for  the Laskin/Poplar  site had  been filed in court, but not yet
signed  by the  affected  parties,  and  penalty  monies  had  not actually  been
collected.  There is, therefore, some degree of uncertainty regarding the final
resolution of this  case.

     It is important for the reader to understand that the dollar figures cited
in  the  Annual Report  for AOs, RI/FS  Settlements,  and RD/RA  Settlements are
estimates made by  the  Regional officials.   In most cases  these  are  not actual
monies  collected  for the Superfund,  but rather  are estimates  of the amount of
money saved the Federal Government by  having the  responsible parties perform the
cleanups.  Regional officials stated that the estimates are based on normal costs
to clean up sites  similar to  those  in  question, unless more specific information
is available to be used.  We requested source documents to validate the amounts
of  these  estimates in Regions  4  and  5, but Regional officials  were unable to
provide any documentation.
                                      F-12

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                 Progress Toward Implementing Superfund: Fiscal Year 1988


     The  Annual Report  presents enforcement  accomplishments  in  a number of
different  categories,  based on official  Agency definitions  and  statistics
tracking.  It is important for the reader to understand that the same Superfund
site may appear in more  than one category.  For example in Region 5, the American
Anodco,  Inc.  site was  counted in  both  the  Administrative  Order and  RI/FS
Settlement categories.  Thus, the reader should not add together the numbers of
accomplishments  in the  different categories  to  form a picture of  the overall
enforcement accomplishments  at  Superfund sites during FY88.

     Annual Report Chapter  11.0 ~ Technology-Related Research and Development

     We  reviewed the information presented in  the  Annual  Report on  the SITE
Program.  Concurrent with our review of the Annual Report, the OIG was conducting
a survey of the SITE Program.  To determine if the information presented on the
SITE Program was reasonable  and accurate,  we asked the auditors working on the
SITE Program survey to analyze this chapter.  Based on their review, we believe
that the information  presented  on the  SITE Program is generally reasonable and
accurate.

     Annual Report Chapter 14.0  -- Executive  Branch Estimate  of Resources  Needed to Complete
     Superfund Implementation

     We did not perform in-depth audit work on the information in this chapter.
Much of  it consists  of  FY88 obligations,  the  resource  estimates  from  the FY89
Operating Plan, and the  Agency's budget request for FY90, all of  which is readily
available information.  Further, section 14.3,  on the Agency's estimate of post-
FY90 costs to clean up the existing NPL, was added to the draft report after we
completed our  field work.   Consequently,  we  did not have sufficient  time to
perform an in-depth review  of this  information prior to the Agency's scheduled
issuance  of  the  final  report.   However,  we do  wish  to  emphasize  that  the
projected dollar  figure of approximately $18.6 billion does  not  address  sites
which are not presently proposed for listing or  actually on  the NPL.

     Annual Report Preparation Process

     As with last year's Annual Report, the process used to prepare this year's
was not fully effective.  Although this Annual Report was due to Congress January
1, 1989, it was not submitted to OMB for review until September 1989, one month
later than last year's report.   While the Agency improved the overall timeliness
of issuing the report, it was still not completed until December 1989.   Many of
the reasons for  the Annual Report's  lateness are the same  as  last year.  These
issues need to be addressed if future Annual Reports are to be submitted timely
to Congress.

     Part of the reason that the Annual Report encountered such difficulties is
that the  coordinator's  resources were limited,  thus inhibiting the completion
of the prior year's Annual Report.   In  fact, while we were performing our review
of the FY88 Annual Report the  coordinator was still devoting much  of  his time
to the FY87 Annual Report. We finished almost all of our field work for the FY88
review prior to the Agency's transmittal of the FY87 Annual Report to Congress.

     Another factor contributing to the Annual Report's delay was the fact that
the coordinator was unable to secure  selected accomplishment figures  in a timely


                                      F-13

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


manner from  Agency offices responsible  for compiling them.   For example, as
previously discussed, we were initially unable to  secure  CERCLIS printouts  from
OSWER two months after the end of the fiscal year,  due to "data discrepancies."

     Accurate  and complete  monitoring  information  is  not available  to  the
signatory officials.  The Director, Office  of Emergency  and Remedial Response,
has a tracking system to monitor the status and progress  of the Annual Report.
However,  the tracking system available for  the Administrator and  the Assistant
Administrator for OSWER is incomplete and inaccurate.   In June 1989, we secured
a printout from  the  "Statutory Deadlines Tracking System," which contained no
record of the FY88 Annual Report.  Furthermore, the printout showed that the  FY87
Annual Report  was  completed on  February  26,  1988, when,  in  fact,  it was not
signed by  the  Administrator  until over a  year  later.    Without  accurate  and
complete monitoring  information,  officials  responsible  for signing the Annual
Report cannot ensure it is completed on time.

     Finally, we are concerned that delays in the  FY88 Annual Report will delay
future Annual Reports past the January due date to Congress. Preparation of the
FY89 Annual Report did not begin until past  the point  in  time necessary to  meet
the GERCLA deadline.

     CERCLA  states  that  the  authorizing  committees  in Congress will   hold
oversight hearings after receiving the Annual Report, to ensure that the statute
is being  implemented according  to  the  purposes  of the  law and  congressional
intent.  The delay  in  issuing the FY88 Annual Report will not only delay  that
oversight process, but also did not afford Congress the opportunity to consider
any needed action during the FY90  appropriations cycle.
                                      F-14

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         Progress Toward Implementing Superfund: Fiscal Year 1988
•0
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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


                                  APPENDIX G

                                LIST OF SOURCES
     The  following is  a  list  of  reference  sources  that  were used  in  the
preparation of this Report.  Sources for data  used in graphics within the  text
are cited on the  graphics  and also listed below.  Other references were used for
background information and also for fiscal year accomplishment data.
Statutes

Comprehensive Environmental Response, Compensation, and Liability Act,  P.L.  96-
     510 (11 December 1980), 42 U.S.C. § 9601 et.  seq.

Resource Conservation and Recovery Act, P.L. 94-580 (21 October 1976), 42 U.S.C.
     §6901 et. seq.

Superfund Amendments and Reauthorization Act,  P.L.  99-499 (17 October 1986), 42
     U.S.C. §11001 et. seq.

Rulemakings

Carcinogen Reportable Quantity Adjustment; Final Rule  (Draft).

"Designation of Extremely Hazardous  Substances as CERCLA Hazardous Substances;"
     Proposed Rule, 54 FR 3388 (January 23, 1988).

"Technical Assistance  Grants  to  Groups at  National  Priorities  List Sites,"
     Interim Final Rule with Request for Comments,  53 FR 9736 (March 24, 1988).

"Reporting Continuous Releases of Hazardous  Substances;" Proposed Rule,  53 FR
     12868 (April 19, 1988).

"Citizen Awards for Information on Criminal Violations Under Superfund," Interim
     Final Rule, 53 FR 16086 (May 5, 1988).

"National Priorities List for Uncontrolled Hazardous  Waste Sites  Subject to  the
     Subtitle C Corrective Action Authorities of the Resource Conservation  and
     Recovery Act;" Proposed Rule, 53 FR 23978 (June 24,  1988).

"Reporting Exemptions for Federally Permitted Releases of Hazardous Substances;"
     Proposed Rule, 53 FR 27268 (July 19, 1988).

"Arbitration  Procedures  for Small  Superfund  Cost Recovery Claims,"  Proposed
     Rule,  53 FR 29428 (August 4,  1988).

"Acquisition Regulation;" Final Rule, 53 FR 31871  (August 22, 1988).
                                      G-l

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX G
                                LIST OF SOURCES
                                   (continued)
"National Oil  and Hazardous Substances  Pollution  Contingency Plan;"  Proposed
     Rule, 53 FR 51349 (December 21, 1988).

Reportable Quantity Adjustment  - Radionuclides; Final Rule; 54 FR 22524 (May 24,
     1989).

Memoranda

Memorandum; Subject:  The Role of Expedited Response Actions Under  SARA;  From:
     Henry L. Longest II, Director, Office of Emergency and Remedial  Response;
     To: Advisees; OSWER Directive 9360.0-15; OERR; April 21, 1987.

Memorandum;  Subject:   Removal Program  Priorities;  From:    J.  Winston Porter,
     Assistant Administrator; To:   Regional Administrators, Regions I-X;  OSWER
     Directive No. 9360.0-18; OSWER; March 31, 1988.

Memorandum; Subject:  Proposed  Expedited Response Actions at NPL Sites  in Region
     VII; From:   David A.  Wagoner,  Director, Waste Management Division;  To:
     Henry L. Longest, II,  Director,  Office of Emergency and Remedial  Response;
     OSWER Directive 9360.0-1;  Region VII; May 20,  1988.

Reports

Superfund Program Report--Regional Branch Chiefs, Quarterly Update, OERR.

OERR Monthly Management Reports, September 30, 1988.

"Superfund:   Interim Assessment of EPA's  Enforcement  Program;" United States
     General Accounting Office, Report No. RCED-89-40BR, October 12,  1988.

"FY  1988  Enforcement  Accomplishments   Report;"   Office  of  Enforcement  and
     Compliance Monitoring, December 1988.

"The Superfund Report as of September 30, 1988;" OSWER, December 29,  1988.

National Response Team, Annual Report to Congress,  1988, March 1989.

FY88 ROD Summary Report, HSCD/OERR, March 1989.

Progress Toward Implementing Superfund:   Fiscal Year 1987, OERR, April 1989.

Guidance Documents and Directives

Superfund Remedial Design and Remedial Action Guidance, OSWER Directive 9355.0-
     4A, OERR, June 1986.
                                      G-2

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX G
                                LIST OF SOURCES
                                   (continued)
Preliminary Assessment Guidance  for Fiscal Year 1988, OSWER Directive 9345.0-
     01, OSWER, January 1988.

Guidance on Preparing Superfund Decision Documents:   The Proposed Plan and the
     Record of Decision (Review Draft), OERR, March 1988.

Guidance for Conducting Remedial  Investigations and Feasibility Studies Under
     CERCLA (Draft), OSWER Directive 9355.3-01, OERR, March 1988.

Catalog of Superfund Program Directives,  OSWER Directive  9260.7-01, OSWER, July
     1988.

Procedures for Completion and Deletion of National Priorities List Sites (Draft) ,
     OSWER Directive 9320.2-3A, OSWER, September 1988.

Interim  Guidance  on Administrative Records  for  Selection of  CERCLA Respone
     Actions, OSWER Directive 9833.3A, OERR, March 1, 1989.

Other Sources

Management of  Construction  in the Superfund Program  (Training booklet), HSCD,
     July 31, 1986.

"The New Superfund:   Protecting  People and Their  Environment;" EPA Journal,
     Office of Public Affairs, January/February 1987.

"Superfund:  Looking Back,  Looking Ahead;" Reprinted from EPA Journal,  Office
     of Public Affairs, April 1987.

"Federal Facilities Added to  the  National  Priorities List;" 52 FR 27620 (July
     22, 1987).

Pre-Remedial Strategy for Implementing SARA, OSWER Directive 9345.2-01, OSWER,
     February 12, 1988.

"Federal Agency Hazardous Waste Compliance Docket;"  EPA  initial  list of Federal
     Facilities Under CERCLA  Section 120(c), 53 FR 4280  (February 12, 1988).

Community Relations in Superfund:  A Handbook (Interim Version),  OSWER Directive
     9230.0-3B, OERR, March 1988.

Potential  Changes  in the  Composition of  the National  Priorities  List After
     Revisions of the HRS (Draft),  May 25,  1988.

"Office of Solid Waste and Emergency Response Training Plan;" Office of Program
     Management and Technology, May 27, 1988.
                                      G-3

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
                                  APPENDIX G
                                LIST OF SOURCES
                                   (continued)
Options for Setting the Cutoff Score for the  Revised HRS  (Draft),  OERR, May  31,
     1988.

National Priorities List,  Supplementary Lists  and Supporting Materials, OERR,
     (HW-10.35) June 1988.

Background Information:  National Priorities List, Proposed Update #7/RCRA Rules,
     OERR, June 1988.

"EPA revises  policy for  listing RCRA  sites on NPL,"  Hazardous Intelligence
     Materials Reports, August 5, 1988.

"The National Priorities List for Uncontrolled Hazardous Waste Sites  -- Criteria
     for Determining Unwillingness for Sites Subject to the Subtitle C Corrective
     Action Authorities of the Resource Conservation and Recovery Act;". Policy
     Statement, 53 FR 30005 (August 9,  1988).

"The National Priorities List for Uncontrolled Hazardous Waste Sites -- Additions
     to Policy for Determining Inability-To-Pay for Sites Subject to the Subtitle
     C Corrective Action Authorities of the Resource Conservation and Recovery
     Act;" Policy Statement for Comment, 53 FR 30002  (August 9,  1988).

Removal Actions Universe Study, Emergency Response  Division, August 18, 1988.

"The Superfund  Enforcement Process:   How It Works;"  Office of Waste Programs
     Enforcement, Summer 1988.

CORAS Bulletin, CORAS/OPM/OERR, Volume  1, Issue 1,  September 1988.

Fact Sheet for Revisions to the National Oil  and Hazardous  Substances Pollution
     Contingency Plan (Draft), September 1,  1988.

"National  Oil  and  Hazardous Substances  Contingency Plan;  National Priorities
     List  Update,"  Notice of  Deletion  of  Sites from  the  National Priorities
     List, 53 FR 33811  (September 1, 1988).

Hazardous Waste Report, Volume 10, Number 1, September 5,  1988.

"Superfund Program  Status:   Regional Branch Chiefs Quarterly Update;" OSWER,
     October 24, 1988.

Superfund  Site  Completions and  Deletions  from the  October  25,   1988 National
     Priorities List,  HSCD/OERR, October 25, 1988.
                                      G-4

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX G
                                LIST OF SOURCES
                                    (continued)
"Federal Agency Hazardous  Waste Compliance Docket;" First  six-month update of
     list of  Federal Facilities Under  CERCLA Section 120(c) and  revisions to
     initial list, 53 FR 45364  (November  16,  1988).

"1989-1993 Training  Strategy;"  OSWER.

Active Superfund Contractor Listing FY 1988-1989, EPA Office of Administration.

EPA Superfund Budget Documents.

List of FY88 Requests, Superfund Docket and Information Center.

Superfund Comprehensive Accomplishments Plan.

CERCLA Information System.

EPA Contract Laboratory Program, Sample Management Office.

Removal Tracking System, Emergency Response Division.

U.S. Environmental Protection Agency  Strategic  Planning and Management System.
                                      G-5

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988


                                  APPENDIX H

                             LIST OF ABBREVIATIONS
AA

A/E

ABNs

ARE

ANPRM

AOB

ARARs

ARCS

ARIP

ASTSWMO


ATS

ATSDR

BBS

BDAT

BUREC

CA

CAA

CAP

CDC

CDMS

CERCLA


CERCLIS
Assistant Administrator

Architectural/Engineering

Acid and Base/Neutral Compounds

Acute Hazardous Events

Advance Notice of Proposed Rulemaking

Analytical Operations Branch

Applicable or Relevant and Appropriate Requirements

Alternative Remedial Contract Strategy

Accident Release Information Program

Association of State and Territorial Solid Waste Management
Officials

Action Tracking System

Agency for Toxic Substances and Disease Registry

Bulletin Board System

Best Demonstrated Available Technology

U.S. Bureau of Reclamation

Cooperative Agreement

Clean Air Act

Capacity Assurance Plan

Centers for Disease Control

Cost Documentation Monitoring System

Comprehensive Environmental Response, Compensation,  and
Liability Act of 1980, as amended

CERCLA Information System
                                       H-l

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                 Progress Toward Implementing Super-fund: Fiscal Year 1988
                                  APPENDIX H
                             LIST OF ABBREVIATIONS
                                    (continued)
CERI        --  Center for Environmental Research  Information

CERT        --  Council of Energy Resource Tribes

CHRIS       --  Chemical Hazard Response Information System

CIS         --  Contract Information  System

CLP         - -  Contract Laboratory Program

CMS         --  Corrective Measures Study

COE         --  U.S. Army Corps of Engineers

CORA        --  Cost of Remedial Actions

CPCA        --  Core Program Cooperative Agreements

CWA         --  Clean Water Act

DERP        --  Defense Environmental Restoration  Program

DOD         --  Department of Defense

DDT         --  Dichloro-diphenyl-trichloroethane

DOC         - -  Department of Commerce

DOH         --  Department of Health

DOI         - -  Department of the Interior

DOJ         --  Department of Justice

DOL         - -  Department of Labor

DOT         - -  Department of Transportation

DWEL        --  Drinking Water Equivalent Level

EDA         --  Emergency Declaration Area

EE/CA       --  Engineering Evaluation/Cost Analysis

EHS         --  Extremely Hazardous Substance

EMSL        - -  Environmental Monitoring Services  Lab
                                       H-2

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
EMS-LV



EPA

ERAs

ERGS

ERD

ERNS

ERRIS

ERT

ESAT

ETP

FAA

FDER

FEMA

FFA

FIFRA

FIT

FMS

FOIA

FTE

FTTA

FY

GAO

GIGS
                                  APPENDIX H
                             LIST OF ABBREVIATIONS
                                    (continued)
Enviromental Monitoring  Systems  Laboratory in Las Vegas,
Nevada

Environmental Protection Agency

Expedited Response Actions

Emergency Response Cleanup  Services

Emergency Response Division

Emergency Response Notification  System

Emergency and Remedial Response  Information System

Emergency Response Team

Environmental Services Assistance  Teams

Emerging Technologies Program

Federal Aviation Administration

Florida Department of Environmental Regulation

Federal Emergency Management Agency

Federal Facility Agreement

Federal Insecticide, Fungicide and Rodenticide Act

Field Investigation Team

Financial Management System

Freedom of Information Act

Full-Time Equivalent

Federal Technology Transfer Act

Fiscal Year

General Accounting Office

Grants Information Control  System
                                       H-3

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
GSA

HAZMAT

HHS

HRS

HRSD

HSED

HSRC

HSWA

IAG

IFR

IG

IRON

IRM

IWT

KPEG

LOE

LSI

LTRA

MARAD

MBDA

MBDCs

MBEs

MCLs

MCLGs
                                  APPENDIX H
                             LIST OF ABBREVIATIONS
                                   (continued)
General Services Administration

Hazardous Materials

Department of Health and Human Services

Hazard Ranking System

Hazardous Response Support Division

Hazardous Site Evaluation Division

Hazardous Substance Research Centers

Hazardous and Solid Waste Amendments  of  1984

Interagency Agreement

Interim Final Rule

Inspector General

Interagency Report Control Number

Initial Remedial Measure

International Waste Technologies

Potassium Polyethylene Glycolate

Level of Effort

Listing Site Inspection

Long-Term Response Action

Maritime Administration

Minority Business Development Agency

Minority Business Development Centers

Minority Business Enterprises

Maximum Contaminant Levels

Maximum Contaminant Level Goals
                                       H-4

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
MOU

MSIS

NAAG

NAMC

NBARs

NCP



NEIC

NEPA

NFRAP

NGA

NIEHS

NOAA

NPL

NPRM

NRC

NRT

NTP

NYSDEC

O&M

OAQPS

OECM

OERR

OGC
                                  APPENDIX H
                             LIST OF ABBREVIATIONS
                                    (continued)
Memorandum of Understanding

Marine Safety Information System

National Association of Attorneys General

National Association of Minority Contractors

Nonbinding Allocations of Responsibility

National Oil and Hazardous Substances  Pollution Contingency
Plan

National Enforcement Investigation Center

National Environmental Policy Act

"No Further Remedial Action Planned"

National Governors Association

National Institute for Environmental Health Sciences

National Oceanic and Atmospheric Administration

National Priorities List

Notice of Proposed Rulemaking

National Response Center

National Response Team

National Toxicological Prograir

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 General Counsel
                                       H-5

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
OHMTADS

OHRM

DIG

OMB

OMSE

OPA

OPMT

OPPE

ORC

ORD

ORP

OSC

OSDBU

OSHA

OSR

OSWER

OU

OWPE

PA

PADER

PAHs

PAS

PASS

PCBs
                                  APPENDIX H
                             LIST OF ABBREVIATIONS
                                   (continued)
Oil and Hazardous Materials Technical Assistance Data  System

Office of Human Resource Management

Office of the Inspector General

Office of Management and Budget

Office of Management Systems Evaluation

Office of Policy Analysis

Office of Program Management and Technology

Office of Policy and Program Evaluation

Office of Regional Counsel

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

Operable Unit

Office of Waste Programs Enforcement

Preliminary Assessment

Pennsylvania Department of Environmental Resources

Policyclic Aromatic Hydrocarbons

Policy and Analysis Staff

Procurement Automated Source System

Polychlorinated Biphenyls
                                       H-6

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX H
                             LIST OF ABBREVIATIONS
                                    (continued)
PHRED       --  Public Health Risk Evaluation Data Base

PIC         --  EPA Public  Information  Center

POTW        --  Publicly Owned Treatment Works

PRP         --  Potentially Responsible Party

RA          - -  Remedial Action

RAG         --  Response Action Contractor

RASs        --  Routine Analytical Services

RCRA        --  Resource Conservation and Recovery Act

RCRIS       --  Resource Conservation and Recovery Information System

RD          --  Remedial Design

REM         --  Remedial Planning  (Contract)

RFI         --  RCRA Facility Investigation

RI/FS       --  Remedial Investigation/Feasibility Study

ROD         --  Record of Decision

RPM         --  Remedial Project Manager

RQ          --  Reportable  Quantity

RRTs        --  Regional Response Teams

RSPS        --  Regulatory  and Special  Project Section

RTS         --  Removal Tracking System

SAB         --  Science Advisory Board

SAGA        --  Support Agency Cooperative Agreements

SARA        --  Superfund Amendments and Reauthorization Act of 1986

SASs        --  Special Analytical Services

SBA         --  Small Business Administration
                                       H-7

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988
SCAP

SCDHEC

SCEES

SCOR

SDC

SDIC

SDWA

SETS

SI

SIC

SITE

SMOA

SMCRA

SPHEM

SPMS

SSCs

SSI

STSP

SWCB

SWDA

TAGs

TAT

TCEA

TDD
                                  APPENDIX H
                             LIST OF ABBREVIATIONS
                                   (continued)
Superfund Comprehensive Accomplishments Plan

South Carolina Department of Health and Environmental Quality

Superfund Cost Estimating Expert System

Site Close Out Report

Settlement Decision Committee

Superfund Docket and Information Center

Safe Drinking Water Act

Superfund Enforcement Tracking System

Site Inspection

Standard Industrial Classification

Superfund Innovative Technology Evaluation

Superfund Memorandum of Agreement

Surface Mining Control and Reclamation Act

Superfund Public Health Evaluation Manual

Strategic Planning and Management System

State Superfund Contracts

Screening Site Inspection

Superfund Technical Support Program

State Water Control Board

Safe Drinking Water Act

Technical Assistance Grants

Technical Assistance Team

1,1,1-Trichloroethane

Telecommunications Device for the Deaf
                                       H-8

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                 Progress Toward Implementing Superfund: Fiscal Year 1988
                                  APPENDIX H
                             LIST OF ABBREVIATIONS
                                    (continued)
T&E         --  Test and Evaluation

TES         - -  Technical Enforcement  Support

TIB         --  Toxics Integration Branch

TPDs        - -  Training Planning Documents

TPQ         --  Threshold Planning Quantity

TSCA        --  Toxic Substances Control  Act

TSDFs       --  Treatment,  Storage,  or Disposal  Facilities

TSP         --  Technology  Support Project

USCG        --  United States  Coast  Guard

USDA        --  U.S. Department of Agriculture

UST         --  Underground Storage  Tank

VA          --  Veterans Administration

VOCs        - -  Volatile Organic Compounds

VORCE       - -  Volume Reduction/Chemical Extraction Process

VORRP       --  Volume Reduction Research Project

WBEs        --  Women's Business Enterprises

WQC         --  Water Quality  Criteria
                                       H-9

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                 Progress Toward Implementing Superfund:  Fiscal Year 1988

                                  APPENDIX H
                             LIST OF ABBREVIATIONS
                                    (continued)

                              STATE ABBREVIATIONS
AK
AL
AR
AS
AZ
CA
CO
CM
CT
DE
FL
GA
GU
HI
IA
ID
IL
IN
KS

KY
LA
MA
MD
ME
MI
MN
MO
MS
Alaska                         MT
Alabama                        NC
Arkansas                       ND
American Samoa                 NE
Arizona                        NH
California                     NJ
Colorado                       NM
Commonwealth of the Marianas   NV
Connecticut                    NY
Delaware                       OH
Florida                        OK
Georgia                        OR
Guam                           PA
Hawaii                         PR
Iowa                           RI
Idaho                          SC
Illinois                       SD
Indiana                        TN
Kansas                         TTPI

Kentucky                       TX
Louisiana                      UT
Massachusetts                  VA
Maryland                       VI
Maine                          VT
Michigan                       WA
Minnesota                      WI
Missouri                       WV
Mississippi                    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
Trust Territory of the
Pacific Islands
Texas
Utah
Virginia
Virgin Islands
Vermont
Washington
Wisconsin
West Virginia
Wyoming
                                       H-10
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