United States        Office of Emergency and     EPA/540/8-90/005
            Environmental Protection    Remedial Response       April 1990
            Agency          Washington DC 20460

&EPA      Status of State
            Involvement in the
            Superfund Program
            FY 80 to FY 89

                                        April 1990
                     FY 80 to FY 89
                       April 1990
         Office of Emergency & Remedial Response
              Hazardous Site Control Division
                 Washington, D.C. 20460
                             U S  Environmental Protection Agency
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This document has been reviewed in accordance with the U.S. Environmen-
tal Protection Agency's peer and administrative  review  policies and ap-
proved for publication. Mention of trade names or commercial products does
not constitute endorsement or recommendation for use.

                          TABLE OF CONTENTS

                                                                       Page No.

List of Exhibits and Charts                                                     v

I.     FRAMEWORK FOR THE STUDY                                       2

      A.    State Roles in Response                                           2
      B.    Sources of Information                                           4
            1.     Agency Databases                                          4
            2.     Federal Statutes and Regulations                              5
            3.     Sources of Information Beyond EPA                           6

II.    OVERVIEW OF THE SUPERFUND PROCESS                             6

      A.    Identifying Sites                                                 6
            1.     General Accounting Office                                   7
            2.     Office of Technology Assessment                             7
            3.     Association of State and Territorial Solid Waste Management
                  Officials                                                 11
      B.    Assessing the Site                                               11
      C.    Listing on the NPL                                               13
      D.    Implementing the Remedy                                         13
      E.    Initiating a Removal                                              13
      F.    Pursuing Enforcement                                            13


      A.    States' Role in Pre-Remedial and Remedial Response                    15
            1.     Pre-Remedial Accomplishments                              15
            2.     Remedial State Accomplishments                              19
      B.    States' Role in Removals                                          19
      C.    States'Role in Enforcement                                        23
      D.    States' Role in Operation and Maintenance                             23
      E.    Site Accomplishments                                            23

IV.   STATE INVOLVEMENT IN THE CORE PROGRAM                        25

V.    SUMMARY                                                          27

APPENDIX A - References                                                    28

                          EXHIBITS  AND  CHARTS
                                                                           Page No.

      Exhibit 1

      Exhibit 2

      Exhibit 3

      Exhibit 4


      Chart 1

      Chart 2


      Chart 4


      Chart 6



      Chart 9

      Chart 10

      Chart 11
CERCLIS Codes to Track Lead Responsibility

Estimates of Potential Hazardous Waste
Sites Vary Among Organizations

Overview of the Superfund Process

Obligations to States by Regions Through
Cooperative Agreements from FY 81 - FY 89
Total CERCLIS Inventory of Sites has Grown

Perspectives Differ on the True Number of
Hazardous Waste Sites

Pre-Remedial Process May Lead to NPL

Sites Placed on the NPL Represent a Minimal
Proportion of the CERCLIS Inventor

Significant Progress in Conducting PA's
Leaves Fewer Sites to Address

SI Accomplishments Have Followed
Fluctuations in Funding Levels

Total Number of Completed State-lead
Remedial Activities Has Increased

State-lead Efforts at Ongoing Remedial Activities Have

State-lead Sites Contribute to CERCLA RA
Start Goals

Site Accomplishments by States, EPA, and Others

The Core Program Continues to Expand













This study was directed by Jan H. Baker, Chief of EPA's State Involvement Section with
assistance from John Banks and staff in EPA Regional offices. Booz • Allen & Hamilton Inc.
contributors to this report included Robert France, Pamela Bellin, and Verna Montgomery. The
authors would also like to acknowledge and thank staff at the Association of State and Territorial
Solid Waste Management Officials and in State Superfund programs for their contributions.


                                FY 80  - FY 89
       When Congress first enacted the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) in 1980, it provided EPA and the States with
the authority and approach for responding to uncontrolled hazardous waste sites.  In 1986
Congress amended CERCLA and passed the Superfund Amendments and Reauthorization
Act of 1986 (SARA), which was distinguished from the original law in its emphasis on
State involvement in virtually every phase of response. This report provides a concise
summary of State involvement throughout the Superfund process since the passage of
CERCLA, as well as an historical perspective on program milestones and issues that have
influenced State involvement.

       CERCLA, as amended, authorizes the Federal Government to assume lead
responsibility for cleanup at a site (Federal-lead), or to transfer the, necessary funds and
management responsibility to a State when it has the technical and administrative
capabilities to lead all or part of a Superfund response (State-lead). Section 121 (f) of the
law mandates that EPA provide "substantial and meaningful involvement by each State in
initiation, development, and selection of remedial actions to be undertaken in that State."
These remedial actions involve a full range of activities undertaken at hazardous waste sites
to abate or permanently clean up waste threatening human health and the environment. The
intent implicit in the statute is to strengthen the EPA/State partnership in the Superfund
program. Over the past four years, EPA has made a conceited effort to provide States with
a greater role in the program, increased responsibility for cleanup decisions, and additional

       Involvement by non-Federal entities in Superfund response extends to States,
political subdivisions, and federally recognized Indian Tribes. Provisions for the
involvement of these parties are contained primarily at Sections 104,121, and 126 of
CERCLA, as amended; Subpart F of the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) (40 CFR Part 300); and the administrative regulation for
Cooperative Agreements and Superfund State Contracts for Superfund Response Actions
(40 CFR Part 35 Subpart O).  It should be noted, that the discussion here is focused on
State involvement in the Superfund program.

       During the course of implementing CERCLA, EPA is often asked questions on
what State involvement in the Superfund program has been  to date. The purpose of this
report is to address many of these questions by presenting detailed information on State
Superfund activities. These include participation in site-specific activities during each
phase of response as well as in non-site-specific activities that are essential to the
functioning of State Superfund programs. To assess the changing  roles played by States,
current as well as historical levels of State participation are presented in this document.
This information provides an indication of the States' abilities to assume responsibility and
input to future directions in State involvement. In  A Management  Review of the
Superfund Program (The Superfund 90-Day Study), the Agency's Administrator identified
the need for EPA and States to develop joint short- and long-term strategies to enhance
State program capability, improve State performance at State-lead Superfund sites, and
foster State remedial activity at sites not on  EPA's National  Priorities List (NPL).  This

report provides an historical perspective with which to explore future implementation
strategies for EPA and States, and to respond to the Administrator's recommendations in
the 90-Day Study.

       The report is organized into the following discussions:

       •       The overall framework for the study, including the roles and responsibilities
              of States considered in the report and the sources of information that were

       •       An overview of the Superfund process and the phases of response

       •       An historical perspective on State involvement in each phase of response at
              Superfund sites

       •       A summary of State involvement in non-site-specific activities, specifically
              those funded through the Superfund Core Program

       •       Summary and future use of information gleaned through this analysis.

       Throughout the report charts and graphs summarize the patterns of State-lead
involvement and broader-based program activities related to these activities. Each chart and
graph is accompanied by a set of bullet points that briefly describes the importance of the
graphic, the historical context including program milestones that may have impacted State
involvement, and interpretations of the data, as appropriate. In most cases, data used in
this report were extracted from EPA's official Superfund database: the CERCLA
Information System (CERCLIS) as of October 1989.

A.    State Roles in Response

       Many different parties may assume the lead for all or part of a Superfund response
action. Historically, EPA has been the lead agency for the majority of Fund-financed
response activities, however, other Federal entities such as the U.S. Army Corps of
Engineers and the Federal Emergency Management Agency have taken the lead for
portions of the response on a regular basis and have worked with EPA to ensure that
appropriate remedies are implemented.  States, political subdivisions thereof, and federally
recognized Indian Tribes can take the lead and have been increasing their Superfund
participation in this capacity over time.  Finally, Responsible Parties (RPs) for a site can be
compelled under both Federal and State statutes to assume responsibility for cleanup.

       This report focuses on State-lead activities, which can include an array of
responsibilities. State activities can include both direct, site-specific response or oversight
of RP cleanup actions. Each of these activities may be Fund-financed. In a limited number
of cases, there have also been mixed funding scenarios involving work performed by a RP.
Throughout this report, references are made to State, Federal, RP and other leads.  This
report has defined the term "lead agency" as the entity responsible for the activity when it
was completed. Activity takeovers in which lead responsibility has shifted from one entity
to another are not distinguished. Exhibit 1 summarizes the types of lead

                                      Exhibit 1

               CERCLIS Codes to Track Lead Responsibility
                   Fund-financed response actions
                   PA.SI, RI/FS, RD, RA and removal activities

                   Non-Fund-financed response actions
                   State-funded PA, SI, Rl/FS, RD, RA and removal activities

                   Fund-financed response actions with concurrent enforcement
                   activities by the State
                   Enforcement activities initiated by a State using its own
                   enforcement authorities such as RI/FS and RD/RA
                   negotiations and administrative order issuance

                   Non-Fund-financed, State oversight of RP actions
                   State has administrative or judicial order requiring RPs to
                   conduct response.
                   No Federal concurrence on the remedy

                   Pre-authorization Mixed Funding (Fund/Responsible Party)
                   work performed by PRP under a Federal decree with an
                   agreement that the Fund will provide reimbursement to
                   the PRP (applies to response  events).

                   Fund-financed response actions
                   PA, SI, RI/FS, RD, RA and removal activities

                   Fund-financed enforcement activities with concurrent
                   activities by EPA/DOJ
                   Enforcement activities initiated by EPA such as PRP searches,
                   RI/FS and RD/RA negotiations and cost recovery activities

                   EPA in-house actions
Non-Fund-financed response actions
Activities performed by the RP under Federal order
All other Fund and Non-Fund-financed activities
Includes entities such as other Federal agencies, Federal
facilities, the U.S. Coast Guard, and the  U.S. Army Corps of

that are represented throughout this report when referring to State, Federal, RP or other
lead agencies and the codes in CERCLIS by which these activities are tracked.

       State involvement in the Superfund program is not limited to State-lead response
actions but also includes State resources and efforts dedicated to administering State
Superfund programs and to support agency activities. State involvement in the Superfund
Core Program is one measure of State involvement in non-site-specific administrative
activities that enable States to be active in site-specific response. State participation in the
Core Program is also portrayed in one section of this report. This report does not address
State involvement in a support role given the scarcity of information available and the
necessary limitations of the study.

B .    Sources  of Information

       Information on State involvement in the Superfund program was gathered from
many different sources in compiling this report. Multiple EPA databases were assessed to
determine whether they contained appropriate information on State activities; Federal
statutes and regulations were reviewed to consider their impacts on State initiatives; and
studies conducted by offices within EPA and outside organizations were carefully
assessed. Each of these told one part of the story of State involvement in the Superfund
program, and provided input to this assessment of the status of State activities.

       1.     Agency  Databases

       Four EPA databases were investigated as sources of information on State
involvement in Superfund cleanup:  the Grants Information and Control System (GIGS);
the Regional Automated Grants Document Subsystem (RAGDS); the Integrated Financial
Management System (TFMS); and the official Superfund database, the Comprehensive
Environmental Response, Compensation, and Liability Information System (CERCLIS).
The purpose of each database and its relevance to this effort are described below.

       GICS tracks the processing of all EPA grants applications, prospective wastewater
treatment construction projects, and active grants projects in the Agency. GICS is an
assistance agreement database tracking obligations and general project information. It also
tracks major changes in projects, such as extension of time, increased funding, or changes
in the scope of work, though these are not coded by phase of response. GICS data were
used to help identify funding levels of Cooperative Agreements (CA) for States discussed
later in this report.

       RAGDS, a subsystem of GICS, downloads grants record information stored in
GICS to a personal computer environment so that a user can easily merge information into
text. RAGDS did not provide data for use at this juncture.

       IFMS is the official information system used for EPA's accounting and financial
reporting activities.  In this report, IFMS data on Federal funding to States for Superfund
activities was collected and compared with CERCLIS and GICS data to help assess the
total funding to States through Superfund Cooperative Agreements.

       CERCLIS provides detailed information on removal, remedial, and enforcement
actions taken by States, EPA, RPs, and other entities involved in the Superfund program.
CERCLIS currently serves two purposes: it contains an inventory of potential hazardous
waste sites and serves as the vehicle for Regional reporting to Headquarters on the status of
major cleanup activities at each site.  Activities tracked in CERCLIS include:  Preliminary
Assessment (PA), Screening and Listing Site Inspections (SSI and LSI; herein referred to
as SI), Remedial Investigation/Feasibility Study  (RI/FS), Remedial Design (RD), and

Remedial Action (RA).  CERCLIS also tracks data on awards to States through Superfund
Cooperative Agreements to conduct these activities. After comparing IFMS, GICS, and
CERCLIS information on funding to States, CERCLIS data were determined to be the
most complete and therefore are reflected in this report. Currently, efforts are underway to
improve the completeness of information that is tracked on these awards and the
consistency of information among these databases.

       CERCLIS tracks activities by start and completion dates. A start date demonstrates
that funding has been set aside for the activity, but, does not guarantee that any action has
been initiated. Completions, on the other hand, reflect accomplishments in meeting targets
established as part of EPA's Superfund Comprehensive Accomplishments Plan (SCAP).
The SCAP is the Agency's official planning tool used to determine the level of funding for
each Region,  a decision that is based on the number of planned completions for each Fiscal
Year (FY).

       The information  in this report focuses on State-lead completions to highlight State
accomplishments and is  based primarily on CERCLIS data from FY 80 through FY 89.
Reviewing the magnitude of ongoing activities in each year, however, provides insight to
the resource demands on State programs at a single point in time. Ongoing activities can be
calculated using a statistical reporting language and CERCLIS data and are shown in one
chart to depict the level of State involvement in the implementation of remedial response
(e.g., RI/FSs, RDs, and RAs).

       CERCLIS became EPA's official tracking system for Superfund activities in FY
87. In the early years of the program variations in Regional input and modifications to the
system impacted the type and quality of CERCLIS data. The integrity of CERCLIS data
has, in fact, improved significantly since those early years. The CERCLIS Management
Council (CMC) was established to help coordinate the efforts of CERCLIS users and to
make recommendations  on proposed system changes and enhancements. The CMC's
objectives for enhancing data quality has been twofold: verify historical data and encourage
effective use of the data to improve future data integrity. Although data quality is a priority,
there are still inconsistent input methods by the Regions that should be considered when
drawing conclusions. To ensure that more recent data accurately portray progress in
Superfund implementation, data quality reviews are now being performed. CERCLIS,
nevertheless, provides the most comprehensive site-specific information available on
Superfund response activities.

       2.    Federal  Statutes and Regulations

       It is important to consider the statutory mandates and implementation guidelines that
have directed State Superfund programs when looking at the status of State involvement.
Therefore, in preparing this report, a review was performed of the relevant statutory and
regulatory requirements  to understand the historical, current, and future issues facing the
States.  The overall goals and objectives for State involvement in responding to
uncontrolled hazardous waste sites were established by Congress in CERCLA, as
amended, and impacted in some areas by the requirements of the Resource Conservation
and Recovery Act (RCRA). The structure and function of State programs working to meet
these objectives has been influenced by regulations such as:

       •      "The National Oil and Hazardous Substances Pollution Contingency Plan"
             (40 CFR  Part 300)

       •      The administrative regulation for "Cooperative Agreements and Superfund State
             Contracts for Superfund Response Actions" (40 CFR Part 35 Subpart O)

       •      "The Uniform Administrative Requirements for Grants and Cooperative
             Agreements to State and Local Governments" (40 CFR Part 31).

       State accomplishments and the level of State participation in Superfund cleanups
must be considered in the context of these and the various other regulations that have
impacted their activities over time.

       3.    Sources of  Information Beyond EPA

       Other Federal offices such as the General Accounting Office (GAO) and the Office
of Technology Assessment (OTA) have performed independent reviews of EPA's
Superfund program.  In addition, several studies have been conducted by State
representatives through the Association of State and Territorial Solid Waste Management
Officials (ASTSWMO). Each of these studies looked at different questions, such as what
is the actual number of sites requiring response, what mechanisms are in place for States to
respond at NPL versus non-NPL sites, and how might changes in Federal policy impact
State involvement Data gathered in these efforts and the conclusions made in these
studies were taken into account in assessing the overall status of State involvement in the
Superfund program in this report.  (See Appendix A for a complete reference list.)

A.    Identifying Sites

       Since 1980, more than 30,000 hazardous waste sites have been reported to EPA
and entered into the inventory of potential Superfund sites, which is tracked in CERCLIS.
The requirements of the NCP contained at 40 CFR 300.405 describe the various methods
for discovering releases including: normal reporting requirements under CERCLA,
investigations by government authorities, notifications by Federal or State permit holders,
surveys or incidental observations, and submissions of citizen petitions.

       The 30,000 CERCLIS sites have been identified primarily as a result of the
Agency's reporting requirements under RCRA and CERCLA. Many of these were
identified as a result of the provisions of CERCLA Section 103(c), which required all past
and present owners and operators of facilities where hazardous substances were stored,
treated, or disposed of, to notify EPA by June 1981 of the existence of such facilities and
of any known, suspected, or likely releases of hazardous substances at those facilities.
EPA received about 5,000 reports of such facilities that were entered into the site inventory.

       CERCLA created a tax on the chemical and petroleum industries for implementing
the Superfund program that was to be accumulated over a five-year period, collection of
which began in 1981. However, in the early years of the program the financial base for
conducting pre-remedial activities was limited.  As a result, delays were experienced in the
discovery, inspection, and evaluation of hazardous waste sites. To  address these delays,
Congress added Section 3012 to the 1980 amendments to RCRA, requiring  each State to
compile an inventory of all hazardous waste sites within the State. Although no
appropriation was made until September 30,1982, Congress authorized ten million dollars
from the Fund to implement Section 3012. This one-time appropriation assisted States in
completing a site survey and inspection at potential Superfund sites. In this one instance,
EPA waived any cost-sharing responsibilities for the States, believing that any cost share
would be difficult for the States to obtain in light of the relatively short time  frame in which
financial assistance had to be allocated. Together, these statutory authorities have provided
a basis for EPA's efforts to define the number of hazardous waste sites that  should be

investigated and evaluated for CERCLA-funded response.  Chart 1 summarizes the steady
progress EPA has made in identifying these sites; for example, EPA received over 3,000
notifications of hazardous substance releases in 1985 alone.

       To gain a clearer understanding of the types of sites in the CERCLIS inventory and
the most successful means of identifying these sites, EPA's Site Assessment Branch,
within the Office of Emergency and Remedial Response, has been conducting a CERCLIS
Characterization Study involving a review of all sites discovered and placed in inventory.
The study includes 11 reports which review sites in CERCLIS: ten Regional reports and
one national report. The study indicated that 32% of the sites identified in the CERCLIS
inventory were a result of State and local inspection and assessment programs. It also
found that a State was the owner/operator at only 1.3% of the sites at the time of its
contamination. Further investigation on the CERCLIS universe is currently being
performed as part of this study and additional conclusions are expected to be released in
early 1990. In addition, a similar study is planned to assess the composition of NPL sites.

       Although the CERCLIS inventory of sites totals roughly 30,000, several
organizations have developed different figures as depicted in Chart 2.  The GAO, OTA and
ASTSWMO have projected the total number of hazardous waste sites to range from
approximately 8,000 to 425,000. Each study has a slightly different focus. GAO
considered the total universe of hazardous waste sites; OTA considered the number of both
hazardous and non-hazardous waste sites; and ASTSWMO looked at the potential number
of NPL sites in the future based on known and suspected releases. These studies reveal
that the extent of the nation's potential hazardous waste problem may be larger than is
currently indicated by EPA's inventory of sites in CERCLIS.  The considerations taken
into account in each study and the size of the hazardous waste universe projected by each
are summarized in Exhibit 2 and are discussed in more detail below.

       1.     General Accounting Office

       In 1987, GAO reviewed EPA's study for Congress, Extent of the Hazardous
Release Problem and Future Funding Needs. CERCLA Section 301fa¥l¥c^ Study and
other EPA reports to evaluate independently the number and types of sites that may need to
be considered potential hazardous waste sites. On the basis of EPA and other Federal
agency data, GAO estimated that there may be 130,300 to 425,000 potential hazardous
waste sites that qualify for inclusion on the CERCLIS inventory.

       An August 1989, report by GAO, State Cleanup Status and Its Implication for
Federal Policy, acknowledged that States face a complex cleanup job at thousands of non-
CERCLA sites. States reported to GAO that they have completed approximately 7% of all
cleanups or 760 sites of their approximately 28,000 known or suspected hazardous waste
sites.  GAO recommended that EPA reexamine the nature, form and extent of EPA's
technical assistance to States and EPA Regions and implement a strategy for more effective
delivery of such assistance. To promote protective, consistent cleanups of Superfund sites,
GAO also recommended that any deferral policy adopted by EPA include requirements for
State eligibility, that State cleanups be at least as stringent as EPA requires, and that EPA
monitor State  cleanups of sites deferred from placement on the NPL.

       2.     Office  of Technology Assessment

       OTA examined the universe of operating RCRA hazardous waste facilities as well
as EPA's site inspection (SI) process to estimate the number of sites that could become
future NPL sites in its 1985 report Superfund Strategy. OTA believes that at least 5,000 of
the 621,000 operating and closed solid waste facilities in this country, such as sanitary and
municipal landfills, may qualify for CERCLA-financed cleanup. In addition, OTA found

Number of
Sites in
             35000 r
                                                  Chart 1
                                   Total CERCLIS Inventory of Sites has
                                            Grown Substantially
                            ("~| New Sites
                            • Cumulative Inventory
                     1980    1981    1982    1983
                                       1984   1985
                                        Fiscal Year
1987   1988   1989
                This chart illustrates both annually and cumulatively, sites with a discovery date in the
                CERCLIS inventory

                From 1980 to 1989, the total number of sites in CERCLIS has more than tripled

                Initial fluctuations in the number of sites in CERCLIS resulted from:

                    - Statutory requirements passed in 1980 requiring owners and operators to notify
                     EPA of possible releases (CERCLA, Section 103 (c))

                    - Only sites named as top priority sites by States were included from FY 80 - FY 82

                   - Reductions in the cumulative CERCLIS inventory of sites following periodic
                     screening to eliminate sites that did not meet CERCLIS criteria

                   - Implementation of Section 3012 in RCRA in FY 83, requiring States to bring additional
                     sites to the attention of EPA for placement on the hazardous waste site inventory

                An increasing need for pre-remedial activities by States and EPA has accompanied
                this growth in the CERCLIS inventory.

                                 Chart 2

                     Perspectives Differ on the True
                   Number of Hazardous Waste Sites
             130,000 - 425,000 potential sites in the U.S
                                ASTSWMO:             b
                   22,881 suspected sites nationwide
                               ASTSWMO:             b
                   7.900 confirmed sites in 46 States
                 8,000 additional potential NPL sites
                             1,224 NPL sites
•  There are many different perspectives on the number of hazardous waste sites that
   exist; therefore, the potential burden of hazardous waste sites on States can be
   interpreted differently by various groups

•  This report focuses on activities within the EPA universe of National Priority List (NPL)
   sites tracked in CERCLIS

   The number of NPL sites reflect EPA's proposed NPL Update # 9, as published in the
   Federal Register July 1989, the last published NPL for FY 89.

a: 'Extent of the Nation's Hazardous Waste Problem is Still Unknown," GAO, December 1987.
b: "State Programs for Hazardous Waste Site Assessment and Remedial Action," ASTSWMO, June 1987.
c: "Superfund Strategy," OTA, April 1985.

                                            Exhibit 2
                         Estimates of Potential  Hazardous Waste
                             Sites Vary Among Organizations
The General Accounting Office developed an estimate of
potential hazardous waste sites through their review of:
   Non-hazardous RCRA Subtitle D

   Hazardous RCRA Subtitle C facilities

   Mining waste sites

   Underground Storage Tanks

   Pesticide-Contaminated Sites

   Federal Civilian facility sites

   Federal Defense facility sites

   Radioactive releases

   Underground injection wells

   Town gas facilities

   Wood preserving plants


           818 (a)



         3,920 (b)

         1,882 (c)






 (a) Project failures of facilities under RCRA financial assurance
 (b) Number of sites in six States where pesticide levels are known
    to exceed State standards.
 (c) Includes 171 municipal landfills or dumps that also may be
    included in the estimates of RCRA Subtitle D facilities.
The Office of Technology Assessment
examined hazardous & non-hazardous
sites and the SI process to assess future
sites that may require cleanup including:

•  Solid but not hazardous     5,000
   waste facilities governed
   by Subtitle D of RCRA

•  Hazardous waste facilities   1,000
   regulated under Subtitle C
   of RCRA

•  Sites in EPA's inventory of  2,000
   hazardous waste sites that
   may warrant cleanup with
   a revised SI procedure
                      The Association of State and Territorial
                      Solid Waste Management Officials
                      conducted a survey of State hazardous waste
                      programs identifying:

                      •   Hazardous waste sites with         7,900
                         known releases

                      •   Hazardous waste sites with       22,881
                         suspected releases

                         TOTAL                  7,900-22^81

that at least half (or 1,000) of the approximately 2,000 operating hazardous waste facilities
that are, or should be, subject ttfRCRA groundwater protection standards will become
NPL sites.  After reviewing EPA's SI process, OTA suggested that changes to it could
merit an additional 2,000 sites requiring cleanup. Therefore, OTA believes an additional
8,000 sites may merit cleanup, resulting in an NPL of about 10,000 sites.

       In 1989, OTA published a report which reiterated its concern that cleanups
occurring outside of Superfund, under other Federal and State programs, may one day
result in a new class of contaminated sites for which cleanup has been mismanaged.  In the
report, Coming Clean. Superfund Problems Can Be Solved. OTA suggests coordinating
actions among cleanup programs by establishing national cleanup standards and a Federal
site discovery program.  OTA also identified widespread interest in stronger enforcement
to encourage financing of cleanups by Responsible Parties.

       3.     Association of State and  Territorial Solid Waste Management

       ASTSWMO's 1987 survey of State Superfund program  officials found 7,900 sites
with known releases in 46 States, with an average of 172 confirmed sites per responding
State. These included both NPL and non-NPL sites. Ninety percent of the currently
confirmed 7,900 hazardous waste sites are not on the NPL and,  therefore,  not currently
eligible for Federal funding. Among the 7,900 sites, there were leaking underground
storage tanks, surface impoundments, solid waste landfills, and industrial or commercial
facilities.  States and/or Responsible Parties must address these sites.  ASTSWMO found
an additional 22,881 sites with suspected releases, in 40 States with an average of 572 per
responding State. According to the States, approximately 40% of all sites will need
cleanup in the future. States estimated that for every known site, there are  three suspected
sites. As more and more of these are found,  the CERCLIS  inventory will grow increasing
both the demand for resources and the need for EPA/State coordination in response.

       Identification of hazardous waste sites is an important issue that concerns many
groups within as well as outside the Agency. EPA recognizes these differing
interpretations of the number of hazardous waste sites and continues to strive for a
thorough Superfund site identification and evaluation process. What follows is a
description of the Superfund response process following site identification.

B .    Assessing the  Site

       The response process established by the NCP for handling hazardous waste
problems is triggered by the discovery of hazardous wastes sites.  Site-specific response
begins with evaluating, on a preliminary basis, the danger posed to human health and the
environment by the site. EPA, or a State that takes the lead under a Cooperative Agreement
with EPA, determines whether hazardous substances at the site are uncontained and/or
contaminating soil, ground water, or the air.  This evaluation progresses through a series of
assessments, leading to NPL placement or non-CERCLA status (Chart 3).

       The first step, a Preliminary Assessment (PA) uses readily available information to
determine whether emergency action is called for, additional investigation is needed, or the
site is not eligible for CERCLA-funded action. Over 60% of EPA's inventory of sites has
received PAs as a result of the Agency's process for evaluating potential site problems.

Pre-Remedial Process May Lead to NPL
The process of discovering and evaluating
Superfund sites goes through a series of phases
that may lead to placement on the NPL

The pre-remedial process has resulted in the
placement of 1,224 sites on the NPL, and the
determination that 10,069 sites do not qualify for
Fund-financed CERCLA remedial actions
(Called "Non-CERCLA" sites)

Differences between phases and the number of
Non-CERCLA sites are a result of evaluations
that are underway or pending for 19,932 sites

Sites that are not placed on the NPL become the
responsibility of the States and others.

       If the assessment reveals a serious problem, the lead agency performs an SI to
determine if there is any immediate danger to persons living or working nearby.  The site
inspection process actually consists of two steps: a Screening and then a Listing Site
Inspection. This information is then used to determine if the site warrants inclusion on the
NPL. Over 10,000 sites have been investigated and evaluated to determine if the problems
they posed were serious enough to merit Superfund action.  As of July  1989, 1,224 final
and proposed sites were identified by EPA as national priorities and thereby eligible for
Federally funded response (Chart 4).

C.    Listing on the NPL

       EPA has a ranking system for determining which sites are eligible for inclusion on
the NPL, called the Hazard Ranking System (HRS). This screening tool is designed to
take into account a  standard set of factors related to risks from potential or actual migration
of substances through ground water, surface water, and air. HRS scores range from 0 to
100. Sites scoring  28.5 and above on the current HRS are eligible for the NPL.

D.    Implementing the Remedy

       Once the national priority of a site has been determined, an investigation of the extent
of the contamination and an analysis of the range of alternative remedial actions is
conducted. Both EPA and the State can act as the lead or support agency in these remedial
activities. The first stage of remedial response, called the Remedial Investigation/Feasibility
Study, involves an examination of site data to identify alternatives for remediation. The lead
agency for the cleanup then compares the advantages and disadvantages of each option. If
the State is not the lead agency for response, it has the opportunity for review and comment
as prescribed in Subpart F of the NCP.  Once a preferred approach is chosen, a
recommendation for action is made to the Assistant Administrator for Solid Waste and
Emergency Response and a Record of Decision (ROD) is signed.  The remedy must now be
designed in detail and constructed, otherwise known as RD/RA. The last Fund-financed step
of the remedial action is to ensure that the remedy is operational and functional which
generally takes place  within one year. For remedies involving ground or surface water
restoration, the operational and functional phase may last up to 10 years or until the level of
protectiveness prescribed in the ROD is achieved, whichever occurs first. The States are
responsible for the  activities after this operation and functional period and all subsequent
operation and maintenance (O&M) required at NPL sites.

E.    Initiating  a  Removal

       When hazardous wastes present an imminent hazard of explosion, air or water
pollution or other emergency that would pose an immediate short-term threat to human
health, EPA has the authority to intervene with a "removal" action. In many cases, removal
actions involve removing contaminants from the problem site and transporting them to
waste disposal sites in compliance with RCRA.   Removal actions may be taken at any
time during the response process whether or not the site is included on the NPL, based on
factors such as:  exposure to human and animal populations or food chains; contamination
of drinking water supplies; threat of fire or explosion, availability of Federal or State
mechanisms to respond to the release; and other situations that may threaten public health,
welfare or the environment.  If contamination remains at the site following the removal, a
more detailed analysis of the contamination may result in further response action.

F.     Pursuing  Enforcement

       Throughout the response process, efforts are made to find individuals or companies
responsible for the contamination and compel them to conduct or pay for the cleanup.


                            Chart 4
            Sites Placed on the NPL Represent
       The Most Significant Sites Identified in the
                     CERCLIS Inventory
To date 1,224 of the 31,225
sites in the CERCLIS Inventory
have been proposed or finalized
on the NPL.
     Sites awaiting or
     currently undergoing
     evaluation: 19,932
                                                    Non-CERCLA sites included
                                                    sites requiring no further
                                                    Fund-financed action: 10,069
      Approximately 4% of the sites in CERCLIS have been listed on the NPL

      EPA utilizes Trust Fund monies for remedial activities only at NPL sites

      Cleanup funds for non-NPL sites are the responsibility of States and

      Trust Fund monies are used for emergency removal activities at both
      NPL and non-NPL sites

      There have been 27 sites delisted from the NPL through FY 89.

States can participate in Federal-lead enforcement actions under Section 121 (f) of
CERCLA. Under Section 106, EPA can issue administrative orders to compel a Potentially
Responsible Party (PRP) to clean up a site where there may be an imminent and substantial
threat to human health or the environment. Under Section 107, EPA may also use
Superfund money for site cleanup and then recover the costs from PRPs through the
courts. Under CERCLA, as amended, the courts can hold any PRP liable for complete
cleanup costs.  A summary of the entire response process is  depicted in Exhibit 3.
                                 Exhibit 3
                         ;»/&¥ OCCUR DltttoK* ALL l»«A$eS       :
 A.    States' Role in Pre-Retnedial  and  Remedial Response

       EPA is authorized under CERCLA Section 104(d)(l) to transfer Federal funds to
States to undertake CERCLA response activities through a Cooperative Agreement.
Exhibit 4 illustrates obligations to States over time through such Cooperative Agreements.
Under this agreement, the State can serve as the lead agency for planning and implementing
the response action at a particular site. For State-lead, Fund-financed actions, the
Cooperative Agreement is also used by EPA to obtain the required States' cost-share and
CERCLA Section 104 assurances. In a Federal-lead response, EPA is the lead agency with
the appropriate State agency providing a support role. For Federal-lead, Fund-financed
remedial actions,  a Superfund State Contract is the mechanism used by EPA to obtain these
assurances. Regardless of the lead agency designation,  CERCLA requires State
involvement in pre-remedial and remedial response activities. To meet the requirements of
CERCLA and strengthen the EPA-State partnership, Subpart F of the NCP spells out the
procedures for EPA and the State in conducting and coordinating response actions, whether
such actions are directed by EPA or the State.

       1.    Pre-Remedial Accomplishments

       States and Federal agencies have evaluated and ranked thousands of potential
hazardous waste sites which have been reported, not as  emergencies, but as long-term
threats to the environment through PAs and Sis.  States  lead pre-remedial activities under
the authority provided in Sections 104(b) and (d) of CERCLA.  For the period FY 80-
FY 89, State-lead PAs totalled over 17,000 and State-lead Sis totalled over 3,000.
Charts 5 and 6 illustrate these cumulatively and the annual State-lead accomplishments for

                              Exhibit 4
      Obligations to States by Regions Through Cooperative
                    Agreements from FY81 - FY89
Total ($)
02,220,61 1
1 ,204,741
1 ,350,245
21 ,447,504
1 ,292,092
1 ,230,624
635,21 C
1 ,033,647
| .:.:.-...-:.:., ..-.., ••:,:.,v •:•,..•• • :, ." . ..;• .;%'_'..,• ,••;••.• •••••,•,...•' .-...•>-••.,. ••-= •"'. .'••.-.•. ••-.:• *.:.-.':-
31 ,242,031
861 ,826


Note: These data were collected from CERCLIS and reflect all obligations to States
through Cooperative Agreements.  Financial data for CERCLIS is entered from the
Financial Management System (FMS).  In FY 89, the Integrated Financial Management
System replaced FMS. However, the transfer of financial data from IFMS to CERCLIS for
FY 89 underestimates the actual obligations to States because of difficulties in sorting data
between the two systems.

Number of
             18000 1
             16000 •
             14000 •
             12000 •
             10000 • •
              8000 • •
              6000 • •
              4000 • •
              2000 • •
                               Significant Progress in Conducting
                               PAs Leaves Fewer Sites to Address
Cumulative State-lead PA Completions
Annual State-lead PA Completions
                    1980    1981    1982   1983    1984    1935   1986   1987    1988    1989

                                                  Fiscal Year
                   For the years FY 80 - FY 83, many RIs were later coded as PAs or Sis in

                   The proportion of sites in CERCLIS with completed PAs grew from 22% in FY 80
                   to 60% in FY 89

                   States have assumed lead responsibility for completing approximately 17,300
                   PAs from FY 80 to FY 89 of the 19,854 completed nationwide

                   States assumed an increasing role in the conduct of PAs after receiving funding
                   under RCRA Section 3012; States led 244 PAs in FY 80 and peaked at 4,271 in

           4000 T
           3500 - -
           3000 - -
           2500 - -
Number of   2000 - •
            1500 ••
            1000 •-
            500 ••
           SI Accomplishments Have
  Followed Fluctuations in Funding Levels
Cumulative State-lead SI Completions

Annual State-lead SI Completions

                                                               \\ f   \ •• Vs      ••

                   1980    1981    1982    1983    1984    1985     1986    1987    1988   1989
                                                   Fiscal Year
                  For the years FY 80 - FY 83, many RIs were later coded as PAs or Sis in CERCLIS

                  Incremental changes in the number of Sis completed are a result of the following

                         RCRA Section 3012 which authorized funds for pre-remedial activities in
                         1982 when many Sis were started; by FY 84-85 these Sis were completed

                         Funds for response were limited during CERCLA reauthorization, resulting in
                         fewer completions in FY 86
                  Over 3,000 State-lead Sis have contributed to the evaluation process leading to NPL

PAs and Sis respectively. After FY 83, there is a significant increase in State
involvement in these activities resulting from increases in funding levels. This
involvement in pre-remedial activities is important for evaluating whether sites merit
further response. Those sites that require further response are placed on the NPL and are
thereby eligible for remedial funding. The following section describes State involvement
in remedial activities following NPL placement.

       2 .     Remedial  State Accomplishments

       Each NPL site presents a unique set of problems and circumstances that must be
addressed by EPA and the States. Developing a workable, permanent solution for
hazardous waste sites requires attention at each stage of the remedial process: RJ/FS, RD
and RA. The design and construction of the remedy can  be managed or overseen by EPA
or the States.  From FY 80 through FY 89, States have completed a substantial number of
these remedial activities (Chart 7).  Because these actions are intended to stop, or
substantially reduce, over the long term a release or threatened release, remedial activities
often take more than one fiscal year to complete. Fluctuations in the magnitude of State-
lead completions need to be considered in the context of the type and duration of the
individual remedies being implemented.  This report does not attempt to comment on the
duration or quality of State- verses EPA-lead remedial activities. While the number of
completed State-lead remedial activities has appeared cyclical, the number of ongoing
activities has appeared to grow over time (Chart 8). The increases in ongoing RI/FSs, RDs
and RAs by States suggest a strong commitment toward long-term cleanup activities. State
contributions to CERCLA activity targets represent further evidence of their commitment to
the remedial program.

       Participation of States in the effort to meet the statutory requirements for RA starts
is important as both Federal- and State-lead sites can be counted toward the RA start goals
set forth in Section 116(e) of CERCLA, as amended. These goals include 175 new RA
starts by October 1989 and an additional 200 RA starts by October 1991. States have
contributed 18 sites to the 1989 goal, for a total of 178 sites, surpassing the goal of 175 RA
starts by three sites (Chart 9). Not only are States contributing to remedial activities, but
they are also involved in the removal and enforcement processes described below.

B.     States'  Role in Removals

       All time-critical removal actions are Federal-lead, as are long-term actions where
response is more extensive than anticipated or exceeds State capabilities.  States may take
the lead for removals  requiring more than six months of planning at both NPL and non-
NPL sites. Long-term removals appropriate for State-lead are those actions where initiation
of cleanup or stabilization efforts may be delayed for approximately six months or more
from the time the threat is discovered.

       States were not authorized to conduct State-lead removals via Cooperative
Agreements until July 1987. To date, State experience in leading long-term actions has
been limited to initial remedial measures under the remedial program and removals that can
be planned in advance. There were two State-lead removals started in FY 88 and
completed in FY 89 and one removal started in FY 89. Relative to the magnitude of State
participation in remedial planning and implementation, State-lead involvement in removals
has been minimal. Recent State comments received by the Agency on the NCP (40 CFR
300) indicate a strong desire for involvement; the Agency is therefore reviewing the
opportunities for further State involvement in several aspects of the removal program.

                                               Chart 7
                                The Total Number of Completed
                         State-lead Remedial Activities Has Increased
          250 -r
          200  --
Number of
          150 --
          100 --
           50  --
             1980    1981     1982     1983    1984    1985    1986    1987    1988    1989
                                             Fiscal Year
              States accomplished 140 RI/FSs, 54 RDs and 30 RAs from FY 80 to FY 89

              As additional sites flow through the response process, the need for remedial activities

              Decreases in remedial completions in FY 85, FY 87 and FY 89 are due to less activity
              during CERCLA reauthorization and delays in remedial action completions

              RI/FS completions may not indicate that a ROD has been signed.

                                 Chart 8
                State-lead Ongoing Remedial Activities
Cf\ •
' Number of Ongoing RI/FSs

• 7



     1980   1981   1982   1983   1984   1985   1986  1987   1988   1989
                               Fiscal Year

   •   State resources are being used for a significant number of ongoing RI/FS activities.
Number of Ongoing RDs

     1980   1981    1982   1983   1984   1985   1986   1987    1988   1989
                               Fiscal Year

      State resources are being used for a significant number of ongoing RDs.
Number of Ongoing RAs
     1980   1981    1982   1983   1984    1985   1986    1987   1988    1989
                               Fiscal Year
      States have shown continuous progress in ongoing RA participation assuming lead
      responsibility for 51 ongoing RAs in FY 89.

                                            Chart 9
                State-lead Sites Contribute to CERCLA RA Start Goals
                                                                1991 = Target of 375
                  175 flA Starts
                  CERCLA Sec. 116 (e)
                  1989 Target
                                            70 Federal Leads
                                        18 State Leads (10.1%)
                                          13 Other Leads
                                          FISCAL YEAR
            The CERCLA Section 116(e) remedial action (RA) start mandate includes goals of 175
            new RA starts by October 1989 and an additional 200 by October 1991

            EPA and States have been involved in co-implementation of CERCLA and working
            towards these targets

            States have contributed 18 sites to the 1989 goal

            Other leads here include:  Responsible Party-lead under State order with EPA oversight,
            Mixed Funding between Responsible Party and EPA, and Federal Facility-lead.
            ("Commencement of Post-SARA Remedial Actions," EPA Report  10/17/89).

C.    States'  Role in  Enforcement

       Enforcement efforts are important to the Superfund program as the cost of cleaning
up all the serious hazardous sites in the country far exceeds Superfund's resources.
CERCLA Section 121 (f) requires EPA to provide for meaningful and substantial State
involvement in Superfund, and at a minimum in remedial activities; EPA has extended this
involvement to enforcement actions as well. To maximize State and EPA resources for
response, EPA's intent is to compel greater PRP participation in site cleanup.  In the
Superfund 90-Day Study,  one of EPA's stated goals was to "mobilize private party
resources to conduct cleanup up front, rather than using the Fund and recovering costs
through litigation later." EPA is encouraging consistent State CERCLA enforcement
actions to enhance PRP confidence in accepting State remedies and settlements. In
addition, by focusing on the successful strategies of States that are willing and able to meet
CERCLA's site-specific or program requirements, EPA may provide an incentive for other
States to expand their programs.

       States may be involved in enforcement activities including: PRP searches and
notification, PRP negotiations for the RI/FS and RD/RA, issuance of administrative or
judicial actions to compel  PRP response actions, as well as settlements and cost recovery.
States may also prepare the ROD at State-lead enforcement sites.  By providing EPA with
an opportunity to concur on the remedy and adopt the ROD, States document EPA
concurrence, thereby providing further incentive for PRP acceptance of remedy decisions.
To date, States have primarily been involved in negotiations and administrative orders.

D.    State's Role in Operation and Maintenance

       States cost share with EPA for the remedial action and operational and functional
(O&F) costs as with other phases of response.  O&F can last up to one year for all
remedies except ground water and surface water restoration for which O&F may last up to
ten years, and is like operation and maintenance (O&M) in its long-term nature. Under
Section 300.435(f)(2) of the NCP and Section 104(c)(6) of CERCLA, O&M begins
immediately after the O&F stage of the remedial action and is entirely the responsibility of
the States. States must assure EPA in a response agreement that they will assume
responsibility for all O&M for the expected life of each remedial action as determined by
EPA and the State. Therefore, at NPL sites, States are responsible for 10 percent of the
remedial action costs through O&F. The long-term nature of O&M will require a
continuing commitment by the  States for years following the completion of remedial action

E.    Site Accomplishments

       States have been involved in all phases of response and thus have contributed to the
implementation of CERCLA, as amended.  The strides in cleanup activity throughout the
nation are measured by the number of sites at which action has been taken and by the
number of these activities. EPA, States and others have shown accomplished signed RODs
at 450 sites; RD completions at 291 sites; and RA completions at  114 sites.  For the pre-
remedial stages, States have completed PAs at almost twice as many sites as EPA and
States have completed Sis and Hazard Ranking at about half as many sites as EPA.
Twenty-seven sites have been delisted from the NPL to date. Chart 10 illustrates these site

                                     Chart 10
           Site Accomplishments by States, EPA, and Others
 Since 1980, together the States, EPA and others have completed remedial actions in 35 States

    - Currently, there are 26 State-lead sites, 41 EPA-lead sites, and 47 sites with remedial
      actions led by others including Responsible Parties, other Federal Agencies, Coast Guard,

EPA and State-lead activities have resulted in the following proportions of signed RODs

    -  52% of all EPA-lead and 25% of all State-lead RI/FSs led to signed RODs

 Removal and enforcement activities can occur at any time and can be concurrent with remedial

 The number of sites delisted to date is 27; 114 have completed RAs and await delisting.

       In response to the statutory mandate for State involvement, EPA developed the
Core Program Cooperative Agreement (CPCA) concept. The Core Program enables EPA
to fund non-site-specific activities that are essential for States to administer their Superfund
program and to play an active role in site-specific cleanups.  EPA's initial policy has been
to provide up to $250,000 per State for such management and administrative support
activities.  CPCAs are negotiated between EPA Regional offices and their respective
States, and are funded annually.

       The actual amount awarded has been based on factors such as a State's Superfund
objectives, the number of CERCLIS and NPL sites in the State not otherwise addressed
under other funding sources, and whether a State program comparable to EPA's Superfund
program is in place. In FY 87, three States were chosen to pilot the Core Program. EPA
developed program guidance based upon the lessons learned during this pilot stage. In FY
88, all States were eligible for Core Program funding, and 37 States applied for CPCAs.
Today 41 States, Puerto Rico, and the Navajo Nation are participating in the Core Program
with total funding at over $11 million (Chart 11).

       EPA recently conducted a review of the Core Program to identify ways in which
CPCAs have enhanced State ability to participate in all phases of the Superfund program,
and to provide EPA Headquarters with a management tool for effectively overseeing the
Core Program. Information gathered during this review identified the following findings:

       •      The Core Program is a success at promoting State involvement and should
              be continued.

       •      Core Program activities vary across Regions, and across States within a
              single Region.

       •      CPCA application and award processes were complicated during the first
              year, but did not inhibit States participation in the Core Program.

       •      Increased Core Program funding would enhance State ability to participate
              in all phases of Superfund response.

       The Core Program has created several primary benefits for participating States

       •      In many States, CPCAs provide the majority of funding for non site-
              specific activity.  The limited State resources  dedicated to these functions in
              the past are now being used for more technical, site-specific activities.

       •       Core Program funds enhance the abilities of States with more mature
              Superfund programs, and provide other States with the support necessary to
              establish a hazardous substance response program.

       •       CPCAs relieve technical site project managers from the burden of
              administrative activities, enabling an appropriate specialization of functions.

                                             Chart 11
                               The Core Program Continues
                                            to Expand
        12,000,000  T
        10,000,000   --
         8,000,000   - -
         6,000,000   - -
         4,000,000   - -
         2,000,000   - -
                                                   Fiscal Year
            Over time, additional States have become involved in the Core Program; hence more Core
            Program Cooperative Agreements (CPCAs) have been awarded:

                  During FY 87 $842,471 dollars were obligated to 3 States through the Core Program

                  During FY 88 $7,445,303 dollars were obligated to 36 States through the Core Program

                  During FY 89 $11,167,142 dollars were obligated to 43 States, Puerto Rico, and the
                  Navajo Nation from Core Program funds.

             Source: Hazardous Site Control Division/ State and Local Coordination Branch

       The Core Program has also created several additional benefits for participating
States. These benefits include:

       •      States have been able to hire and train staff. Resources for new positions
              and training were not available to many States previously.

       •      States have been able to develop financial and procurement systems to
              manage site work more effectively.

       •      Knowledge gained by staff trained to address Superfund sites can also be
              used by States to conduct response activities at non-NPL sites.

       Data from this review were used to revise the regulatory requirements for the Core
Program contained at 40 CFR Part 35 Subpart O. Enhancements and clarification on the
Core Program provided in this rule are intended to foster State programs and the level of
State involvement in site-specific response in the future.
       As the Superfund program continues to address the hazardous waste issue
nationwide, States are assuming an increasingly active role in confronting issues at
Superfund sites. In responding to the recommendations of the Superfund 90-Day Study,
EPA and States will be working together to establish short- and long-term strategies for
State involvement, and to continue co-implementation of CERCLA throughout all phases of
response. This report will be used by EPA as a management tool and updated periodically.

                                APPENDIX A

Association of State and Territorial Solid Waste  Management Officials
(ASTSWMO) Reports:

"State Funding Mechanisms for Cleanup of Non-NPL and NPL Hazardous Waste Sites,"
June 1988.

"State Programs for Hazardous Waste Site Assessment and Remedial Action," June 1987.
United  States General Accounting  Office (GAO) Reports:

"Hazardous Waste Sites: State Cleanup Status and Its Implications for Federal Policy,"
GAO/RCED-89-164, August 1989.

"Superfund: Extent of Nation's Potential Hazardous Waste Problem Still Unknown,"
GAO/RCED-88-44, December 1987.
United  States  Office of Technology Assessment (OTA) Reports:

"Coming Clean: Superfund Problems Can Be Solved...,"OTA-ITE-433, October 1989.

"Superfund Strategy," OTA-ITE-252, April 1985.
United  States Environmental Protection Agency (EPA) Reports and

"A Management Review of the Superfund Program," (The Superfund 90-Day Study),
GPO 623-682/10263, 1988.

"An Analysis of State Superfund Programs: 50 State Study," ELI, August 1989.

"Core Program Cooperative Agreements and Small/Disadvantaged Business Utilization in
Superfund," OSWER Directive 9375.2-04, July 1989.

Enforcement Project Management Handbook. OSWER Directive 9837.2, July 1989.

"Funding for State Core Program Cooperative Agreements State-Specific Additional
Functions," OSWER Directive 9375.2-03, August 1988.

"Guidance for State Core Program Funding," OSWER Directive 9375.2-01, December

"Guidance for State-Lead Removal Actions," Appendix W of the State Participation in the
Superfund Program manual, OSWER Directive 9375.1-4-W, July 1987.

Interim Final Rule on Cooperative Agreements and Superfund State Contracts for
Superfund Response, 40 CFR Part 35 Subpart O.

Fact Sheet on "State and Local Involvement in the Superfund Program", WH/FS 88-009,
Spring 1987.

State Participation in the Superfund Program manual, OSWER Directive 9375.1-5,
February 1984.

The National Oil and Hazardous Substances Pollution Contingency Plan (the NCP), 40
CFR Pan 300.

CERCLIS Characterization Project Briefing to the Director, OERR, Thursday, June 6,
U.S.  Congress Reports:

Committee on Environment and Public Works Conference Committee Report on SARA
outlining the legislative intent of the State participation provisions, Senate Subcommittee on
Superfund and the Environment, Report 99-962.
                                                     & U.S. GOVERNMENT PRINTING OFFICE: 1990/748-159/00474