United States         Office of           SeptemoeM985
•ttnoii r            Environmental Protection    Public Affairs (A-107)
   L • °            Agency            Washington DC. 20*60
 \vcrA       Superfund  Fact book

               Second  Edition       oooR85io4
               September 1985
                         U.S. Environmental Protection Agency
                         Region V, Library
                         230 South Dearborn Street
                         Chicoqo, Illinois 60604

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                            Contents




 HOW SUPERFUND WORKS	,	 1

       CERCLA Authorities  .... 	 1

       Cleanup Actions 	 ......... 2

       Enforcement	3

       Current Budget  .	4

       Proposed Funding Levels 	 . 	 5

       Community Relations	 5

       Progress To Date	...6

CHART:  HOW SITE DECISIONS ARE MADE	9

1935 TESTIMONY OF LEE M. THOMAS on Reauthorizing
      the Comprehensive Environmental Response,
      Compensation and Liability Act of 1980

      February 25	*	  11

      April 25	50

LIST OF EMERGENCY SITES CLEANED UP BY
  SUPERFUND PROGRAM	57

NATIONAL PRIORITIES LIST 	  77

LEE THOMAS LETTERS TO SENATOR STAFFORD AND
  CONGRESSMAN DINGELL  	  99

LIST OF DELAYED ACTION SITES .	105

EPA REGIONAL PRESS CONTACTS  	 109

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Contact Gwen Brown at 202/382-4355
for single copies of this handbook

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              SUPERFUND   FACTBOOK



                      HOW SUPERFUND WORKS




     Among  the  eight major laws administered by EPA are two

designed to manage hazardous waste:  the Resource Conservation

and Recovery Act (RCRA), under which EPA and the states regulate

currently produced wastes, and the Comprehensive Environmental

Response/ Compensation and Liability Act (CERCLA), better known

as the Superfund, which enables EPA and the States to clean up

sites where hazardous wastes were dumped prior to the passage

of RCRA in 1976.


                       CERCLA Authorities

     CERCLA was enacted by Congress in 1980 to address environmental

and public health problems caused by the uncontrolled handling and

disposal of hazardous substances.  It established the Hazardous

Substance Trust Fund and grants EPA three distinct authorities:

     ••  To take short-term and emergency steps to address
        immediate hazards to public health and the environ-
        ment caused by uncontrolled hazardous substances.
        Any site posing an immediate threat is eligible.

     •  To undertake long-term actions to correct more
       . extensive threats to human health and the environ-
        ment as  a result of  improper management of hazardous
        materials.   For long-term cleanup eligibility a
        site must be placed  on the roster of the nation's
        most hazardous waste sites—the National Priorities
        List (NPL).

     •  To require responsible parties (site owners and
        operators or waste generators)  to clean up hazardous
        waste sites,  including NPL sites, by taking enforce-
        ment action  against  them when they can be identified.
                               -1-

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                        Cleanup Actions
     A site can be nominated for action  by  anyone:  an individual
citizen, an activist group,  a corporation,  an EPA regional office
or any level of government.
     Short-term actions, or  "removals",  can be triggered by
burning, leakage or explosion of hazardous  substances,  imminent
contamination of human or animal food chains, pollution of a
drinking-water supply—any immediate or  incipient threat to
public health or the environment.
     Circumstances may require nothing more than erecting a
security fence, isolating a  source from  the elements with an
impervious cover and testing samples of  soil or water.   In other
cases, leaking barrels or contaminated soil may have to be
removed.  Sometimes it may be necessary  to  provide alternate
water supplies or even evacuate nearby residents. ,
     Through July 1985, EPA  initiated emergency actions at 452
sites.  At some 388 sites, action has been  completed, and of
these 289, including two NPL sites, were totally detoxified and
required no further action.   The other 99 sites have been
controlled or contained pending long-term action.  EPA expects
to conduct at least 190 emergency actions in fiscal 1986.
     Long-term actions are generally undertaken at complex sites
where more than six months is needed to  straighten things away.
Each site is selected according to the degree of risk it presents
to public health or the environment.  EPA works closely with the.
states in implementing this  authority—evaluating the problem,

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designing solutions and conducting the actual cleanup.   The

states share responsibility by:

     •  Assuring EPA that the site will be properly maintained
        once cleanup is completed.

     •  Assuring EPA that an acceptable hazardous waste facility
        is available if off-site storage,  treatment or  disposal
        is necessary.

     •  Sharing in the cost, generally 10  percent for actual     _ -
        cleanup, excluding planning.  If. a state or other
        government owned the site at the time of waste  disposal,
        however, its share will be at least 50 percent  of total
        costs.

     As of September 5, 1985 there were 850 sites on the proposed

and final National Priorities List.  Comprehensive engineering

analyses (known as remedial investigation and feasibility studies),

which determine the full facts and best means of proceeding, are

underway at nearly 450 sites.



                          Enforcement

     Enforcement is a major EPA priority under Superfund.  The

agency believes that those who create environmental problems

should correct them wherever possible.  EPA can obtain  cleanup

action by taking the parties to court, reaching an out-of-court

settlement or issuing direct administrative orders where there is

an immediate threat to public health or environment.  These

methods conserve funds for those sites where responsible parties

cannot be found or lack the financial resources to do the job.

     The agency's first priority, however, is to make sure that

any risks are addressed as quickly as possible.  So, if an

immediate threat to public health develops, EPA draws upon Trust
                               -3-

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 Fund money  to  address the hazard at once; who ultimately pays
 is determined  later in cost-recovery procedures.  Under CERCLA
 the agency  can recover up to three times the amount spent at a
 given site  if  an administrative order was issued and responsible
 parties did not comply.
     From December, 1980 through July 31, 1985 the government has
 secured commitments for privately-financed action at 256 sites. -
 with an estimated value of $479 million.  Some $20.5 million in
 Trust Fund money has been recovered from responsible parties.  The
 government has filed 105 civil actions under CERCLA for response
 action and cost recovery.  Some 190 unilateral administrative
 orders have been issued.

                         Current Budget
     EPA's budget for the Superfund program has tripled during
 the past three years,  and the size of its professional staff has
doubled.  The budget has grown from $210 million in fiscal 1983
 to $620 million in fiscal 1985.  As of July 31, the agency had
obligated a total of $1,174 billion for Superfund work.  Most of
 this money is being spent on emergency action or long-term
operations at Superfund sites through contracts with engineering
 and management firms in the private sector or arrangements with
state governments and  federal agencies.
                              -4-

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                     Proposed Funding Levels
      In the budget proposed by the President  for fiscal  1986,
 funding for the Superfund program would rise  to $900  million,  up
 $280 million from last year.  The Administration's  proposed
 CERCLA reauthorization bill, creating a five-year,  $5.3  billion
 trust fund, was introduced to the House on February 22.  A Senate
 bill approving $7.5 billion in taxes over five  years  is  awaiting--
 floor action.   However,  since revenue legislation originates in
 the House,  the Senate must receive the House  bill before submit-
 ting its  own to a vote.   A House  bill has been  reported  out of
 the Energy  and Commerce Committee with a recommended  level of
 $10.1 billion  and is being considered by various other committees.

                       Community Relations
      People living  in communities adjacent  to Superfund  sites are
 obviously affected  by how CERCLA  is  implemented.  The remedial
 process is  lengthy  and  complex at best:  the typical NPL  site
 requires an investment  of four or five years and about $8 million
 for  a complete  clean  up.   Where groundwater is contaminated,  it
 may  take 30 years to  finish  the job.   EPA is, therefore, committed
 to a  thorough public  information program based on candid, two-way
 communication,  with guidelines from headquarters and full resources
 in every regional office.  The program helps EPA understand local
 concerns and assures  citizens a meaningful role in the Superfund
decision-making process.
                              -5-

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                        Progess to Date

     The Comprehensive Environmental  Response,  Compensation,  and

Liability Act authorizes two basic approaches  to  the task  of

cleaning up abandoned hazardous waste dumps.   The first  is short-

term and emergency action for sites that  pose  an  immediate threat

to public health or the environment.   The second  is  a longer-term

cleanup for sites that are complex or extensively damaged  but _  -

which do not necessarily present an imminent danger.


Short-term Emergency Action (as of July 31,  1985)

•  Short-term emergency cleanups have been started at 452  sites.

•  388 sites have either been completed or stabilized.

•  Short-term emergency cleanup actions by fiscal year (FY) were:

           15 in FY 1980
           21 in FY 1981
           58 in FY 1982
          128 in FY 1983
          208 in FY 1984
          153 in FY 1985 to date.

•  Completed short-term cleanups are listed at the end of  this
   factbook.
Long-term (National Priorities List)  Action (as of September 5,
1985)

•  There are 850 current National Priorities List (NPL) sites,
   final and proposed.

•  At 177 NPL sites, short-term emergency cleanups have been
   started to permit us to eliminate any immediate threats to
   health, while we push ahead with engineering plans for
   long-term cleanup.

•  EPA has identified and notified over 8,000 potentially
   responsible parties at 345 sites.

•  Detailed engineering studies have been completed or are under-
   way at 392 sites (350 by the states or EPA and 42 responsible
   party led)
                                -6-

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•  EPA's target for engineering-study starts in FY 1986 is 180,
   and in FY 1987 is 190; both figures include EPA/state and
   responsible-party studies.

•  119 NPL sites have reached the construction phase;  70 of these
   are being carried out by EPA and the states.  The other 49 are
   enforcement-led.

•  EPA's target for construction starts at NPL sites in FY 86 is
   70 and in FY 87 is 152.  These figures include both EPA/state
   and responsible-party cleanups.

EPA's Superfund Resources

•  FY 1983s    $210 million in new budget authority

              725 fulltime-equivalent positions

•  FY 1984:    $460 million in new budget authority (including
              $50 million in requested supplemental funds)

              1,057 fulltime-equivalent positions

•  FY 1985:    $620 million in new budget authority

              1,249 fulltime-equivalent positions
                                 -7-

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                         STATEMENT OF
                        LEE M. THOMAS
                        ADMINISTRATOR
             U.S. ENVIRONMENTAL PROTECTION AGENCY
                          BEFORE THE
          COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS
                     UNITED STATES SENATE
                      FEBRUARY 25, 1985


     Mr. Chairman and members of the Committee, it is a

pleasure to appear before you this morning.  I am here to

honor a pledge I made last year, to submit to you early in

the 99th Congress this Administration's proposal to reauthorize

the Comprehensive Environmental Response, Compensation, and

Liability Act — the Superfund.

     We have learned a great deal about the problem of

uncontrolled hazardous waste sites since Congress first

enacted Superfund just over four years ago.  Much has been

accomplished using the authorities of the original law.  Based

on our first-hand experiences, as well as our vision of the

problem that remains, it is time now to renew this program.

     Let me say at the outset that implementation of Superfund

is the Environmental Protection Agency's highest priority.

Its reauthorization is my own top legislative goal.  I will

work closely with members of this Committee to extend and

improve this vital statute.

     The legislative proposal we are considering today has the

full backing and support of President Reagan as is evidenced by

the fact the President himself transmitted the legislation to you.

As you know, the President again endorsed Superfund reauthorization

in his State of the Union Message earlier this month.
                                -11-

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      Since  1983,  we  have made  substantial  progress  in


 implementing  the  Superfund  law.   Long-term work  is  underway


 at  hundreds of  sites around  the  country.   At  hundreds  of


 others, we have completed emergency cleanups  and eliminated


 immediate threats  to human health and  the  environment.


      The charts before you summarize our progress to date.


 In  a  moment,  I  will  provide  you  with a. thorough  briefing  on


 where we have been under Superfund and  where  we  are going.


      Despite our progress, however, much remains to be  done.


 We  must take all steps necessary to assure that we  do  not


 lose  our momentum.   The legislation we  present today is


 designed to build upon that  momentum.   It  will allow us to


 get the cleanup job  done as  quickly and completely  as  possible.
            »

     Overall, this legislation will give us the  tools  we


 need  to continue implementing Superfund at the accelerated


 pace we established  during the past two years.   Our proposal:


     o Triples  the resources available  for cleaning up


 hazardous waste sites.

     o Focuses  those  resources on the most serious problems.


     o Strengthens our enforcement capabilities  and ensures


 that responsible parties pay for and conduct  more cleanups.


     o Enhances the  roles of both Federal  and State governments'


 in undertaking  response action.


     o Guarantees a meaningful role for affected citizens in


selecting cleanup options.


     o Assures  an adequate,  stable, and equitable financial


base for the program.
                               -12-

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      The $5.3 billion program we propose today, coupled with
 an aggressive enforcement effort, will yield dramatic results
 during the second five years under Superfund.   By the end of
 fiscal year 1990, we project engineering studies — the first
 step in the full cleanup of a priority site ~ will have been
 started at nearly 1,500 sites.   Actual construction will be
 underway or completed at more than 900 sites.   In addition, by
 the  end of fiscal year 1990, emergency cleanup actions at over
 1700 sites will  have been undertaken.
      This  legislation is the product of months of intensive
 effort on  the part of the executive branch.  The bill we
 offer is  a consensus document reflecting this  Administration's
 view of one of the most pressing environmental issues facing
 this nation.
      I  have personally played a  leadership  role in preparing this
 package.   I will  continue to be  involved in  the reauthorization
 of Superfund.
      While  I  am completely comfortable  with  the legislation
 we present  today,  I  will  be candid  with you.   It raises  some
 difficult  issues  with  which Congress must grapple.   It
 recognizes  and respects  our experiences to date,  and suggests
 statutory changes  to allow us to proceed more  effectively
with  the original  challenge  of Superfund.   It  modifies the
 taxing mechanism  in an attempt to provide the  resources  we  will
need to continue getting  the  job  done.
                               -13-

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                     The Response Program
     There can be no doubt that the public recognizes Superfund
as government's primary tool for addressing environmental and
health threats posed by abandoned hazardous waste sites.
Indeed, the legislative history of Superfund centers on
"inactive," "uncontrolled," and "orphan" hazardous waste sites.
     However, response authorities in the present law are
much more sweeping in scope.  They have the potential to
dilute our scarce Superfund resources among non-site-related
releases, situations posing minimal public health threats,
and other circumstances.
     Our proposal focuses those resources on sites that pose
the most serious potential threat:  uncontrolled and abandoned
hazardous waste sites; municipal and industrial waste disposal
facilities; sites regulated under the Resource Conservation
and Recovery Act but held by insolvent firms; and spills and other
releases of hazardous substances.  In addition, the bill permits
the President to take action at any site where the release of
hazardous substances poses the threat of a major public health or
environmental emergency and authorities or capabilties do not
exist  for response in a timely manner.  In focusing our attention,
we establish a more concerted effort to clean up what we  feel
are the most dangerous sites in  the nation*
     In addition to clarifying the scope of  response under
Superfund, our proposal would  improve and  expedite  cleanup
in several ways.  It better defines health-related  authorities
and the agencies responsible for implementing  them.  The  bill
                                 -14-

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authorizes the establishment of benchmark cleanup standards for
short-term and long-term actions.  And it provides limited pro-
tection for cleanup contractors against claims for future response
costs arising out of the work they perform for us.

                  The Enforcement Component
     The enforcement provisions of this bill are critically
important to our overall success in carrying out the second
phase of Superfund implementation.  During the past several
weeks, I have been a visible and vocal proponent of aggressive
enforcement stances in all EPA programs.
     Enforcement was a major theme of my confirmation testimony
before this Committee less than three weeks ago.  Under
Superfund, this bill gives us the opportunity to turn our
words into substantive tools capable of yielding results*
     As we continue to emphasize Superfund enforcement, we
are proposing a series of statutory changes in our bill which*
taken together, will help ensure that responsible parties play
an increasingly important role in cleaning up hazardous waste
sites.  These changes should be viewed within the context of
our continued reliance on the strict, joint and several
liability of responsible parties at Superfund sites.
     Our bill would:
     o Increase all criminal penalties to $25,000, all civil
penalties to $10,000, and create civil penalties  to augment
criminal sanctions where they do not already exist.
                                 -15-

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      o  Expedite  civil  actions by  requiring  that separate suits
 be  brought  against other potentially  liable parties  for contribution
 after judgment or settlement in enforcement actions.
      o  Clarify governmental access and  information-gathering
 powers  and  establish the authority to enforce them.
      o  Preclude  pre-enforcement review  of selected response
 actions while maintaining safeguards against arbitrary and
 capricious  selection of remedies  or use of orders.
      o  Impose Federal  liens for response costs upon  all real
 property owned by responsible parties affected by an agency
 response action.
      8 Clearly establish foreign  vessel owners' and  operators'
 liability for releases from their vessels.
      The above authorities will do a great deal to enhance
 our enforcement  capabilities.  This, in turn, will increase
 our ability to foster  responsible party cleanups and to
 recover costs where site actions  are paid for by the fund.
     Aggressive  enforcement will  supplement the cleanup efforts
 we undertake using the fund.  I expect  responsible parties,
 responding to our tough enforcement posture, to sign settlements
 valued at between $400 million and S500 million during fiscal
year  1986.  That's three times the level of settlements for
 fiscal 1984, which was a record year in itself.
     Private-party cleanups between 1986 and 1990 are expected
 to total approximately $2 billion.  When coupled with fund-financed
activities, this will effectively yield some $7.5 billion in
 total cleanup activity during that second five-year  period.

                               -16-

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                  Federal-State Relationships

      A strong,  clearly defined Federal-State relationship is
 also essential  to the success of our Superfund program.
 Through carefully crafted administrative steps, we have
 delegated substantial decision-making authority to the states
 during the past two years.  Our legislative package complements
 this trend and  prescribes a greatly expanded role for the States.
      The States would become increasingly active partners in
 making Superfund work.   We offer them the opportunity to play
 a  far more substantive role in managing actual site cleanup for
 both short- and long-term actions,  and to have a more meaningful
 stake in the program's cost efficiency.   We would also add clari-
 fying language  to the existing law  allowing cooperative  agreements
 between  EPA and the States to cover more than  one site.   Enforce-
 ment costs would be included in these agreements.
      New language would put an end  to the current preemption of
 State superfund-like  taxing statutes.   States  would be permitted
 to raise revenues dedicated to hazardous waste site cleanup
 activities  without  constraint by similar Federal statutes.
      We  also  look for the  States to take on a  somewhat larger
portion  of  the  Superfund cost burden.  We propose that the
States pay  for  20%  of  the  cost of long-term cleanup at sites
where  the  State  itself  is  not a responsible party.   This
would  be an  increase  from  the current  10% cost-share.
Similarly, we would increase  the State share from 50% to 75%
for cleanup at sites where  the  State  is  the site operator.
                               -17-

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                    Community Involvement
     Since coming to EPA in early 1983, I have been committed
to a meaningful role for affected citizens in the decisions of
the Superfund cleanup process.  Although the current law does
not address this essential element in the cleanup equation, I
established a community involvement policy shortly after
taking over the hazardous waste program.
     That program, and the process of involving citizens in
Superfund activities, has helped those affected by our work to
understand our decisions.  It has also helped us to understand
the concerns of these citizens.
     Our proposal would require that affected citizens be notified
of proposed cleanup action.  They would be given an opportunity
to comment on the proposed action and any alternatives.  The
objective of this amendment is to ensure community involvement
in long-term cleanup actions.
     One thing I learned first-hand as head of the Superfund
program for two years is the deep, genuine concern of citizens
for the health of their families, the maintenance of their
property values, and the protection of their environment.
The public must know that this agency makes  its decisions  in
the light of day, after considering all responsible viewpoints.
This amendment will lend greater credibility to our efforts
to clean up hazardous waste sites.
                                 -18-

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                          Financing
     In the final analysis, realizing all of the goals we
have set for the Superfund program will depend upon an adequate
and stable financial base.  We believe that a blend of taxes
together with interest on the unexpended fund balance and
cost recoveries will give us the resources we need to accomplish
our mission.
     About 90% of the $5.3 billion we project being generated
by this mix of revenue sources over the next five years will
come from taxes.  One-third of these funds will be generated
by feedstock taxes, while two-thirds will come from a waste-end
tax.
     The details of our legislation are set out in the fact
sheet and the section-by-section analysis that I have attached
to my testimony.
     In closing, I want to stress again that our legislative
proposal is a strong and balanced approach to the hazardous
waste site cleanup problem that is before us.  This bill will
triple the resources available to us for cleanup activities,
strengthen our enforcement capabilities to foster private-party
cleanups, and focus all activities on those sites posing the
greatest risks to human health and the environment.
     I am proud to present this legislation to this Committee.
The staff of many agencies have worked very hard putting it
together.  I urge you to consider its provisions carefully
in crafting a bill to reauthorize Superfund.
     Thank you very much.
                                -19-

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             SUPERFUND REAUTHORIZATION FACT SHEET
     President Reagan transmitted to Congress February 22
the Comprehensive Environmental Response,  Compensation and
Liability Act Amendments of 1985.  The bill would reauthorize
Superfund for five years.


                  Summary of Key Provisions

     o Resources; More than triples funds  available for
Superfund activities over current law.  Existing law established
a $1.6 billion trust fund through fiscal year 1985.  The
proposed reauthorization would generate S5.3 billion between
fiscal years 1986 and 1990.  Approximately 90 percent of these
funds would be raised through a tax on petrochemical feedstocks
and the management of all RCRA hazardous wastes (1/3
feedstock; 2/3 waste end).

     o Scope; The proposed bill would concentrate EPA resources
on hazardous waste sites.  These are the sites Congress
originally intended that Superfund focus on.  The response
program in the Administration's bill would address abandoned
and uncontrolled hazardous waste sites, municipal and industrial
waste sites with problems, and sites governed by the Resource
Conservation and Recovery Act but held by  insolvent companies.
In addition, the bill includes a "safety valve" that enables
the President to respond to any hazardous  substance release
that constitutes a major public health or environmental
emergency.

     o Enforcement; The proposed reauthorization contains
several major changes in EPA's enforcement program.  They
are designed to ensure that responsible parties conduct and
pay for more cleanups.  Key enforcement provisions would:

     --Increase all criminal penalties 525,000; all civil
penalties would increase to $10,000.  New civil penalties
would be created to augment criminal sanctions where they do
not already exist.

     —Expedite civil actions by requiring that separate
suits be brought against other potentially liable parties for
contribution after judgment or settlement in enforcement actions,

     —Specifically define governmental access and  information-
gathering powers and establish the authority to enforce them.

     —Impose federal liens for response costs upon all
real property owned by responsible parties affected by an
agency response action.


                                    -20-

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      It  is  expected  that  these  new  authorities will  significantly
 supplement  fund-financed  cleanup  activities.  In  fiscal year
 1986,  EPA expects  responsible parties  to  conduct cleanup
 work  worth  between S400 and  S500  million.  Through 1990, we
 expect these  cleanups  to  total  some S2  billion,  bringing the
 estimated value of all Superfund  activities over the next
 five  years  to nearly $7.5 billion.

      o State  Responsibilities;  The  current law's preemption
 of state superfund-like taxing  statutes would be eliminated.
 States will be able  to raise revenues  for their own  cleanup
 activities.   The proposal also  promotes multi-site cooperative
 agreements  and allows  state  enforcement costs to be  eligible
 for funding.  The  states would  be required to pay an increasing
 share of the  cost  of cleaning up  sites.  The state matching
 share  for sites where  the state is  not a responsible party
 would  increase from  10 percent  to 20 percent.   For  sites
 where  the state is the site operator, the state share would
 increase from 50 percent to 75  percent.

     o Community Involvement; The proposal would make it a
 statutory requirement  that affected citizens be notified of
 proposed cleanup actions.  They would also be given  the
 opportunity to comment on any proposed action and on alternatives.
 This amendment applies to all long-term cleanup actions,
 whether they  are fund-financed  activities or the result of
 enforcement action.

     ° Projections; As a result of  these provisions/ EPA
 projects that through  fiscal year 1990, engineering studies
will have begun at over 1,500 sites.  Actual construction
will be underway or completed at 920 sites.  In addition, we
will have undertaken emergency cleanup actions at 1,741
sites.
                               -21-

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                  SUPERFUND REVENUES  FACT  SHEET


     In designing a tax to raise  revenue  for funding the Superfund
program, EPA sought to meet the following  objectives:

     0  to provide a stable and predictable source of
        revenue;

     •  to broaden the base from which revenue is received;

     0  to minimize adverse economic impacts on  industries;

     0  to impose the tax on the type of  industries and
        practices that have caused the .hazardous substance
        release problems Superfund was designed  to address;

     0  to encourage a reduction in the quantities of
        hazardous waste generated and to discourage the
        management of hazardous wastes in surface impoundments
        and landfills.


     EPA's proposed amendments to Superfund seek to raise
approximately $5.3 billion to finance the program over  the next
five years (from FY 1986 to FY 1990).

     EPA proposes to raise $5.3 billion from three sources:

     1)  Feedstock;  A tax on crude oil and 42 petrochemicals
         and raw materials used in the production of chemicals
         that contribute to the hazardous substance release
         problem addressed by Superfund.

         The feedstock tax base and tax rates are the  same as  the
         current tax used  to finance Superfund since 1980.

         This tax  is designed to raise approximately $300  million
         per year  over the next five years.

      2)  Waste-management;  Revenues  from the management of  hazardous
         wastes.   This  includes a  tax  on  all  hazardous wastes  received
         at a qualified  (i.e., RCRA-permitted) treatment,  storage,
         or disposal unit, as well  as  hazardous  wastes disposed
         of in  the  ocean or exported  from the United States.

         The tax would  be  imposed  on  the  owners  or  operators of
         hazardous waste management  facilities  or vessels, and
         on exporters  of  hazardous  wastes.
                                     -22-

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        The tax is designed to encourage alternatives to land
        disposal by imposing a higher rate on the management
        of wastes in landfills, surface impoundments, waste
        piles and land treatment units.  This provision will
        complement the 1984 amendments to the Resource Conservation
        and Recovery Act, which direct EPA to consider restricting
        certain wastes from land-based units.

        This tax is designed to raise approximately $600 million
        per year over the next five years.

    3)  The remaining $100 million per year would be derived
        from interest on Superfund investments, from fines, and
        from costs recovered from parties responsible for
        hazardous substance releases cleaned up by Superfund.
    Superfund is currently financed primarily by the feedstock
ax identified above in this fact sheet and money from general
evenues (12 percent).  The current tax, thes general revenues,
ftd interest on the fund has raised approximately $1.6 billion
o finance Superfund response activities since 1980.
                                  -23-

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                 SECTION-BY-SECTION ANALYSIS

             EPA 'S PPQPOSFP AMENDMENTS TO CEPCLA
SECTION 1
     Short Title

     The short title of the legislation is the "Comprehensive
Environmental Response, Compensation,  and Liability Act
Amendments of 1985" (CERCLA Amendments).

SECTION 2

     Amendment to CEPCLA

     This legislation, which reauthorizes the Superfund
program from FY 1986 to FY 1990,  amends the Comprehensive
Environmental Response, Compensation,  and Liability Act of
1980 (CERCLA or "Superfund").

SECTION 3

     Statement of Findings and Purposes

     This section sets forth the findings and purposes of
CERCLA.  The maior findings are that —

     o  Releases and threats of releases of hazardous sub-
        stances continue to pose serious threats to ouhlic
        health and the environnent;

     o  A major source of the hazardous substance release
        problem results from releases from uncontrolled
        hazardous waste facilities; and

     o  To protect human health and the environment, a
        comprehensive Federal program is needed.  The oroaram
        must include strengthened enforcement authority, a
        Federal-State partnership and expanded citizen parti-
        cipation for effective response to hazardous waste
        sites and releases or threatened releases of hazardous
        substances.

     The objective of this section is to clarify Congressional
intent that the focus of the Superfund program should be on
responding to releases or threatened releases of hazardous
substances from- uncontrolled hazardous waste sites.
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 SECTION 4

      Pefinitions

      Section 101(14)  lists those substances which are hazardous
 under CERCLA by reference to substances listed under five
 other environmental laws.  Section 101(14)(C)  includes as
•hazardous under CERCLA "any hazardous waste having the
 characteristics identified under or listed  pursuant to section
 3001  of the  Solid Waste Disposal Act ....".

      This amendment would clarify that a substance need not
 be a  "waste" to be considered a CERCLA hazardous  substance
 under this subsection, so lona as the substance meets the
 criteria of  section 3001 of the Solid Waste Disposal Act.

 SECTION 101

      Authority  to Respond

      CEPCLA  section 104(a)(l)  currently authorizes resoonse
 action  "unless  the President determines that such removal or
 remedial action will  be done properly by the owner or operator
 of  the  facility...or  by any other responsible  party."  The
 amendment  would clarify and confirm that the President has the
 discretion to decide  when resoonsible parties  are authorized
 to  conduct cleanup in lieu  of  Fund-financed response.

      This  amendment is not  intended to preclude or discourace
 responsible  parties from conductinc cleanup actions  without
 the formal permission of the Federal  government.   The current
 requirements of section 105 of  CERCLA (Rational Continaency
 Plan) contemplate  a significant  role  for private  parties  in
 response actions.

      The amendment  is  intended  to clarify that  the Federal
 government would  not  be  precluded from conductina  a  response
 action, merely  because resoonsible  parties  have indicated
 some  willingness  to take  some  form  of response  action.  This
 amendment  would confirm that if  the Federal Government
 determines that Federal  response  is needed, the President
 would have the  discretion to determine the  appropriate response
 and to  take action; responsible  parties  would  not  be  authorized
 to forestall Federal  response.

      Scope of Program

      The lancuage  in  the statute  authorizes response  to the
release into the environment of any designated  hazardous
substance, or pollutant or  contaminant which may present a
threat to public health, welfare, or  the  environment.
                                -25-

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     The amendment would focus Superfund response authority
on the problems associated with releases of hazardous substances
from uncontrolled hazardous waste sites.  Specifically, the
amendment would —

     0  delete "pollutant or contaminant" from the Act;

     0  delete "welfare" from the phrase "public health,
        welfare, and the environment" in the Act;

     •  authorize response whenever there is a release or
        substantial threat of a release into the environment
        which may present a "risk" to public health or the
        environment; and

     0  prohibit Superfund response from certain categories
        of releases, unless the President determines that a
        major public health or environmental emergency exists'
        and that no other person has the authority or cap-
        ability to respond in a timely manner —

          ~  from mining activities covered by SMCRA;

              from the lawful application of pesticides
              registered under FIFRA;

              affecting residential, business, or community
              structures when contamination is not caused
              by a release from a hazardous substance
            •  treatment, storage, or disposal facility;

              affecting public or private domestic water
              supply wells when contamination is not caused
              by a release from a hazardous substance  treat-
              ment, storage, or disposal facility;

              from naturally occurrina  substances in their
              unaltered form; and

              covered by and in compliance with  a permit,
              issued under other federal environmental  laws.

     The effect of the amendment would  be to ensure  that
Superfund responses are focused on  those releases of hazardous
substances which present the greatest threat to  public health
and  the environment, and to enhance  EPA's ability to effectively
manaae the program.
                                  -26-

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SECTION 102

     Statutory Limits on Removals

     Section 104(c)(l) of CKRCLA limits removal actions to
six months in duration and SI million in cost unless certain
waiver criteria are met.  These criteria incude:  a finding
that continued action is necessary to prevent or mitiaate the
emergency and to protect public health and the environment,
and that assistance would not otherwise be provided on a
timely basis.  Because of the limits established in this
provision, some removals have been scaled-down below the ,
level needed to achieve a cost-effective response.

     This amendment would provide an additional and independent
criterion for waivino the statutory limits on removal actions
and increase the six month duration limitation to one year.
The new criterion would permit removals to exceed the $1
million cost and one year duration limitations if the response
action is "appropriate and consistent with a permanent remedy."
The amendment would ensure that removals accomplish a more
complete response, if such response is appropriate in that
situation.

     The primary effect of the amendment would be to enhance
the President's ability to choose the most effective response
in removal situations.  Generally, the amendment would allow,
where appropriate, the first operable units of remedial
actions to be considered removals.  This would provide the
Agency with  increased flexibility to auickly initiate the
appropriate  removal.  This ability to implement a response
ouickly would enhance efforts to contain the migration of
hazardous substances.  In turn, this would result in increased
public health and environmental protection and may be less
costly since hazardous substances could be contained before
they miarate to a much larger area recuiring greater response.

SECTION 103

     Permanent Pemedies
     -MWMM«M«M«PIMBM>MH«BM«MI^B»MMIM«P*>MB»                              *

     Section 104(c)(4) of CEPCLA recuires the  selection  of  an
appropriate  remedial  action  that is consistent with  th-e
National Continaency  Plan (NCP) and is cost-effective  in
liaht of concerns about protectina public health  and the
environment, considerations  of Fund-balancing,  and  the need
for immediate action.  There is no explicit  reauirement  that
the selection of a remedial  action take into consideration
permanent solutions or alternative treatment technologies.
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      EPA currently considers  the  lona-term  effectiveness  and
 the  permanence of  alternatives  in its  selection  of  the  appro-
 priate  remedial action.   This amendment  would  provide explicit
 Conaressional  approval of FPA's position and would  allow
 revision of  the NCP to  implement  this  approach to permanent
 remedies.

•SECTION 104

      Offsite Remedial Action

      Section 101(24) of  CERCLA, which  defines  "remedy or
 remedial action",  provides  that additional  threshold criteria
 must  be met  before the President  may undertake off-site
 disposal of  hazardous substances.   This  creates  a bias  aaainst
 off-site disposal  and reflects past Conaressional and EPA
 emphasis on  on-site land disposal  as the preferred  remedial
 action.

      The objective of the amendment is- to eliminate the
 statutory bias  for on-site  remedies by makina  the statute
 neutral  with reaard to on-site or  off-site  remedies.

      Congress,  as  reflected in the 1984  amendments  to the
 Resource Conservation and Recovery Act,  and EPA  have come to
 recoanize  the value of treatment  and other  alternative
 technologies.

      The primary effect  of  this amendment would  be  to reduce
 the proliferation  of sites  requiring monitoring  in perpetuity
 (by consolidatina'wastes  from many sites  into  one laraer and
 closely  monitored  facility), by recognising the  value of
 permanent  off-site  remedies, such  as treatment.

 SECTION  IPS

      National Continaencv Plan (NCP)
     This amendment would (1) eliminate the requirement that
the NCP include at least 400 facilities, and (2) clarify
that States are allowed only one highest priority designation
for the life of the list.

     The deletion of the phrase "at least 400 facilities"
would allow the Agency to select and place on the National
Priorities List, only those facilities which present "the
areatest danger to public health or welfare or the environment.
                                 -28-

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     The second cart of the amendment would be a Conqressional
ratification of E°A's present policy which is to permit the
States to make only one hiahest priority desianation.  This
policy is reflected in th'e most recent proposed revisions to
the NCP.

     These amendments allow the President to effectively
limit the NPL to only those facilities which pose significant
problems to public health or the environment as determined
through Aqency reaulation.

SECTION 106

     Cooperative Agreements

     The amendment would explicitly permit contracts and
cooperative agreements to cover more than one facility, as is
current EPA policy, and clarifies and confirms that response
includes enforcement activities associated with a remedial
or removal action.  The obiective of the amendment is to
facilitate State response activities by permitting States to
enter into agreements covering more than one site, and by
providing Fund money for response actions, including
enforcement activities.

     The 'primary effect of the amendment would be to increase
State participation in response and enforcement activities.
This would increase the overall pace and effectiveness of the
Superfund program.

SECTION 107

     Publicly Operated Facilities

     Section 104(c)(3) of CERCLA requires States to pay at
least 50 percent of response costs for hazardous substance
releases from facilities owned by the State or political
subdivision thereof at the time the release occurred.

     The amendment would change the 50 percent State cost share
to 75 percent and impose the 75 percent or greater cost-share
only at those facilities operated directly or indirectly by
the State or political subdivision.  The test for imposing
the 75 percent or greater cost-share would be related to
operation rather than ownership of the facility at the time
of disposal of hazardous substances.  The cost-share under
this amendment would apply to sites owned and operated by >'
the State;  sites owned by the State and operated by a private
party under a contract or lease with the State; and sites
                                 -29-

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 owned  by  a  private  party  but operated by  the State.  The
 objective of  the  amendment  is  to  impose the cost-share on
 States only in  those  cases  where  the State is  involved in
 the  operation of  the  facility,  either directly or  indirectly.

     This amendment would also clarify that for purposes of
 this amendment  only that  the term facility will not  include
 navigable waters  or the beds underlyina those waters, and  thus
 a  75 percent  cost share would  not he imposed on States for
 response  actions  at such  facilities.

 SECTION 108

     Siting of  Hazardous  Waste Facilities

     Section  104(c)(3) of CERCLA  reauires that States assure
 the  availability  of hazardous  waste disposal facilities  for
 off-site  remedial actions that are in compliance with subtitle
 C  of PCRA.   States  are not, however, required  to nor provided
 incentives  for  creating or  expandina existino  capacity for
 managina  wastes,  or otherwise  provide for future treatment
 and  disposal  of hazardous wastes.  In order to maintain^an
 aggressive  Superfund  procran,  it  is essential  to ensure  that
 States have adeauate  waste  disnosal capabilities.    \     v
                                                      \
     This amendment would provide initiatives  to Statesv-to
 create and  expand capacity  for managina wastes within the
 State  by  prohibiting  the  use of Fund money for resoonse
, actions in.  those  States that- do not assure the, availabili-ty
 of hazardous  waste  disnosal capacity sufficient to handle  "-•
 that State's  needs  durino a period of tine to  be specified
 by regulation.  The amendment  would be effective two years
 after  enactment.

     There  would  be limited exceptions to this prohibition.
 First, the  amendment  would  permit Fund exnenditures for
 alternative drinking  water  or  for temporary relocation of
 affected  individuals  from their homes for up to one year.
 Second, Fund  money  could  be used  to finance a  response action
 in a State  that does  not  provide  the above assurance if  the
 President determines  that a major public  health or environmental
 emergency exists.

     Any  response action  taken where the  State fails to
 assure the  availability of  sufficient offsite  capacity would
 be subject  to a higher cost share.

     The  amendment  would  also  reguire States to pay any  additional
 costs  associated  with transportina wastes outside  the  State's
 boundaries  (or  outside the  reaion, if the State has entered
 into a regional aareement for  hazardous waste  treatment  and
 disposal) in  addition to  the cost of the  remedy.   This  clause
 would  be  effective  upon enactment.
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     The objective of  the amendment  is  to create an economic
 incentive  for  States to expand existina or create new long-
 term in-state  capacity to manage  hazardous wastes.

 SECTION 109

     Community  Involvement

     CERCLA does not presently address  the role of community
 involvement in  response actions.  Existing federal policy does,
 however, provide for an active community role as expressed in
 existina program guidance and the proposed revisions to the
 National Contingency Plan.

     This  amendment would reauire public notification and an
 opportunity for public comment on the proposed action.  The
 primary objective of the amendment is to ensure community
 involvement in  remedial actions taken pursuant to this Act,
 including  Fund-financed and enforcement actions.

     Because the President has already  incorporated the
 reouirements set forth in this amendment in ooeratina ouidance,
 the amendment itself would not impose new responsibilities
 on the federal government.

     The amendment confirms the President's commitment to
 community  involvement in the Superfund proaram.

 SECTION 110

     Health Related Authorities

     Section 104(i) of CERCLA establishes the Agency for
Toxic Substances and Disease Registry (ATSDR).  ATSDR, in
 cooperation with EPA and other federal aoencies, is authorized
 to implement the health related authorities of the Act.
These authorities include the establishment and maintenance
of:  a national registry of diseases and illnesses associated
with and persons exposed to hazardous substances, and a data
base on the health effects of hazardous substances.  CERCLA
does not clearly define specific roles and responsibilities
of ATSDP and EPA in implementina these and other health
 related authorities.

     The amendment would clarify that the primary purpose of
health related "activities is to support response actions
through health assessments,  consultations, and other technical
assistance relating to the health effects of exposure to
hazardous  substances, and to improve the ability to render
future public health recommendations throuah expanding the
existina body of scientific knowledae.
                                -31-

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      In addition, the amendment would clarify existina roles
and responsibilities of ATSDR and FPA in conductina various
health related activities.  Specifically, the amendment would
authorize EPA as well as State and local officials to reauest
that  ATSDR provide health consultations, assessments, and
other assistance to determine the health effects of exposure
to hazardous substances.  ATSDR may provide such assistance.
The President would also he authorized to conduct exposure
and risk assessments at sites where a release has occurred.

      The amendment would not sianificantly affect current
health related activities but it merely provides a
statutory basis for current roles and responsibilities
undertaken by ATSDR and EPA.

SECTION 111
     Compliance with Other Environmental Laws

     This amendment would authorize the President to specify
in the National Continaency Plan (NCP) the extent to which
remedial and removal actions selected under section 104 or
selected under section 106 should comply with applicable or
relevant standards and criteria established under other
Federal, State or local environmental and public health
laws.  The amendment would specify the factors the President
must consider in makina this determination; these include:
the level of health or environmental protection provided by
the standard; the technical feasibility of achieving the
standard; the interim or permanent nature of the response;
the need for expedient action; and the need to preserve funds
to respond to other respond to other releases.

     The objective of the amendment is to clarify and confirm
the President's authority to determine when response actions
should comply with other Federal, State, or local laws, which
is set forth in existing EPA policy.  This amendment confirms
that because of the uniaue statutory provisions of CERCLA,
and requirements for response action that strict compliance
with other statutory provisions is often not appropriate or
necessary.
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SECTION  112

     Actions Under the National Contingency Plan

     Section 107(d) of CERCLA exempts persons from liability
for damages resulting from actions taken or omitted in responding
to hazardous substance releases.

     This amendment would add that persons  (e.g.* EPA contractors
and others) conducting response actions in accordance with the
NCP or at the direction of an on-scene coordinator are also
exempt from liability for future response costs.  This
means that, for example, contractors would not he held liable
for additional response costs at a site if another response
action is taken at a site where the contractor already conducted
a previous action (if a second response action was taken because
the first response was not sufficient to address the problem),
unless the orioinal action was neoligent or intentionally
misconducted.

     The primary effect of the amendment would be to limit
contractor liability for future response costs.  The amendment
would not affect third party liability claims.  Nor would the
amendment affect the liability of oersons liable or potentially
liable under section in?(a) who undertake a response action
under- this act.

Section 113

     Natural Resource Damage Claims

     The amendment would clarify existing language about the
responsibilities of Federal and State natural resources
trustees.  In general, the Federal or State trustee would perform
assessments of damage to resources under its jurisdiction,
except that Federal trustees may perform assessments on behalf
of States and may be reimbursed by States for performing the
assessments.  Neither Federal nor State trustees would be
required to use the damaae assessment reaulations being
prepared by the Department of the Interior, but if they used the
Department of the Interior reoulation the assessment would be
entitled to a presumption of validity.

     The amendment would also eliminate use of the Fund to pay
trustees for damage to natural resources.  Accordingly, all
references to natural resource damage claims against the Fund
would be deleted from the Act.  The ability of Federal and
State trustees to recover damages from responsible parties
under section 107 would not diminished.

     Finally,  Federal aoencies with custody and accountability
for specific Federal facilities would be the sole trustee of
natural resources on, under, or above such facilities for
purposes of CEP.CLA.
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SFCTION
     Response Claims

     Section 111 of CERCLA authorizes parties who conduct
response actions to assert claims against the Fund to recover
necessary response costs incurred in carrying out the National
Contingency Plan.  The procedures to be followed in presentina
and processing these claims aaainst the Fund are set forth in
section 112.  This amendment would clarify and streamline the
process for response claims.

     The amendment would make the follcwino changes:
                            •

     o  Clarify authority to ^reauthorize response claims;

     0  Eliminate provisions for negotiations with responsible
        parties;

     0  Substitute an administrative hearing process for
        claims adjustments and arbitration; and

     o  Clarify time frames for review of claims.

     The availability of response claims can expedite private
oarty cleanup.  Followino preauthorization for all or portions
of the cleanup, private parties can promptly conduct cleanup
action, and bring claims to the Fund when the response action
is completed.

     CEFCLA currently prescribes five steps at a minimum in
the process fron initial presentation of the claim to the
responsible party to final payment of an award,  where
administrative review and judicial appeal are involved the
process nay take as many as eight steps before the claimant
receives final payment of an award.

     The amendments to this section would streamline the
claims procedure.  First, section 111 would be amended to
clarify the authority of the Agency to ^reauthorize response
claims.  Preauthorization can  be used to assure that response
actions are conducted properly/ and that they are limited 'to
available funds.

     Second, the provisions for negotiations with responsible
parties prior to payment of claims would be eliminated.  Such
negotiations as are needed would be conducted prior to pre-
authorization.
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     Third, an administrative hearing process would he sub-
stituted for the arbitration procedure presently provided for
in the statute.  The arbitration procedure is a vestiqe of
certain economic damaqe claims which were not enacted in
1980.  In that the claims procedures will involve only
reimbursement of costs, there is no reason for claims to be
arbitrated.

     Response costs, are not particularly appropriate for
consideration by a panel of arbitrators.

     Fourth, certain ambiguities in the timeframes for
Presidential action would be clarified*

SECTION* 115

     Indian Tribes

     CERCLA is presently silent reaardino the status of tribal
qovernnents and Indian lands.  Current CEPCLA policy, however,
recoonizes tribal Governments as independent sovereiqns with
authority and responsibility over reservations rouahly analoqous
to that of State aovernments.  This means that tribal governments
are subiect to various notification, consultation, health
related activity, and financial and disposal capacity assurance
requirements.

     The proposed amendment would clarify the role of States,
Indian tribes, and the Federal qovernnent for facilities
on Indian lands.  It defines Indian lands to include only
those where there is some type of trust responsibility or
restriction against alienation.

     Subsection (a) would add two new definitions, "Indian tribe"
and "Indian lands."  Both definitions are tied to the United
States trust responsibility.  Not all Federally recoqnized
Indian tribes would be included in the CF.PCLA definition; only
those tribes for which land, is held in trust.

     Section (b) would set forth the procedure for remedial actions
on Indian lands.  Indian tribes would be required to provide
the assurances specified in section 104(c)(3) for sites on
Indian lands.  If the Secretary of the Interior finds that a
tribe cannot provide these assurances, the Department of the
Interior may provide them on behalf of the tribe,  .states
would not be required to provide assurance for sites wholly
on Indian lands.
                                 -35-

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     The amendment authorizes the President to enter into
aoreements with Indian tribes to carry out response actions
under section 104 and the National Continaency "Ian and to
enforce these agreements.  Indian tribes would be reimbursed
from the Fund for reasonable response costs.

     Also, Indian tribes would be notified by the National Response
Center of releases that affect Indian lands.

SECTION 116
     Preemption

     Section 114 (c) of CFRCLA preempts States from requiring;
persons to contribute to any fund desianed to provide compensation
for claims for response costs or damaaes which may be compen-
sated under CERCLA.  The provision is not clear and it has been
argued that the intent of this provision is to preempt States
from imposing State taxes to finance certain CERCLA and
non-CERCLA action.

     The amendment would delete the section which preempts
States from imposing taxes for purposes already covered by
CERCLA.  The objective of the amendment is to ensure that
States may impose taxes to meet Superfund cost-share require-
ments-, and to foster State cleanup at sites not covered by
CERCLA.

     The primary effect of the amendment would be to remove a
potential barrier to the creation of State superfund programs.
The amendment may result in an increase in the number and
pace of hazardous substance response actions undertaken or
partially funded by States since States would be able to
raise funds to assist such hazardous substance response.

SECTION 117

     State Cost-Share

     Section 104 (c) ( 3) (C) ( i ) of CERCLA reouires States to pay
ten percent of costs for remedial actions at privately owned
facilities.

     This amendment would alter the existing- Federal-State
cost-share to reauire States to pay 20 percent of the remedial-
action costs at privately owned sites.  The cost-share for
State or political subdivision sites would be 75 percent
(see section 106. of this Act).

     The objective of this amendment is to reduce the existincr
burden on the Federal government for financing remedial
response actions by recuirina the States to pay a larger
share of costs at privately owned sites.  The amendment is
consistent with an overall noal of these amendments in
increasing the role of the States in conducting response
actions.


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 TITLE  II  —  PROVISIONS  RFLATING  PRIMARILY TO  SKFORCEMENT


 SECTION 201

     Civil Penalties  for Non-Reporting

     Section  103(a) of  CKRCLA  reouires any person  in charae
 of a vessel or facility to notify  the National Response Center
 as soon as the person in charqe  has knowledqe of any release
 of a hazardous substance in an amount that eouals  or exceeds
 the reportable Quantity established under .section  J02.  These
 notifications serve as  one basis for the Federal Government
 to determine whether  response  action is appropriate for the
 release.

     The existing statute provides only criminal penalties
 for failure to report.  This amendment would  increase the
 criminal penalty to 525,000 and  provide additional enforcement
 flexibility by allowing the imposition of a civil  penalty of
 up to ?10,000 per violation.

     The anendnent would enable  the Administrator  to assess
 civil penalties aqqreqatinq less than 325,000 for  such
 violations? penalties aqqreqatinq more than 325,000 may
 be recovered by the Attorney General throuah a civil action.

     Civil penalties for violations of notification requirements
 have several advantaqes:

     First, civil penalties may be imposed in situations where
 the violations do not merit the sanctions associated with •
 criminal violations.

     Second,  when the Federal government takes an  enforcement
 action to compel  private narty cleanup action for  such a
 release, the Federal qovernment may now also seek  penalties
for violations of the notification provision in the cleanup
enforcement action.
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SECTION 202

     Contribution and Parties to Litigation

     This amendment would chance section 107 of CERCLA
to provide a greater decree of finality to settlements reached
with responsible parties, and to expedite private party
cleanup by simplifying the litiaation process in imminent
hazard and cost recovery actions.

     This amendment would clarify and confirm existino law
qoverninq liability of potentially responsible parties in
three respects:

        parties found liable under section 106 or in?
        would have a right of contribution, allowina them to
        sue other liable or potentially liable parties to
        re-cover a portion of the costs paid;

     -  parties who reach a judicially approved good faith
        settlement with the government would not liable for
        the contribution claims of other liable parties; and

     -  where a civil or administrative action is underway,
        contribution actions could be brouaht only after a
        judgment is entered or a settlement in good faith is
        reached.

     The first provision should help to encouraae private
party settlements and cleanups.  Parties who settle or who
pay judgments as a result of litigation, could attempt to
recover some portion of their loss in subsequent contribution
litigation from parties who were not sued  in the enforcement
action.  Private parties may be more willina to assume the
financial responsibility for cleanup if they are assured that
they can seek contribution from others.

     The second provision would help bring an  increased measure
of finality to settlements.  Responsible parties who have entered
into a judicially approved aood faith settlement under the Act
would be protected from payino any additional  portion of
costs to other responsible parties in a contribution action.

     The third provision would allow more  expeditious management
of litigation.  Hazardous waste sites often  involve dozens or
even hundreds of potentially responsible parties with differinc
types and degrees of  involvement  in the facility.  While
the government may sue all potentially responsible parties,
it need not sue all these parties.  It may instead sue a
limited number of parties to secure complete cleanup  or  all
costs of cleanup under the theory of  joint and several  liability.
In some instances these parties  have  in turn sued other
potentially responsible parties  in the same  iudicial  action.
In several cases this has resulted in massive  and potentially
unmanageable litigation.


                                 -38-

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     The amendment would clarify that if an enforcement action
is underway, claims for contribution or indemnification
could not be hrounht until a judgment or settlement is reached.
This change would allow the government to limit the number
of parties in its actions, so that litiaation could be conducted
in a more efficient and expeditious fashion.

SECTION 203

     Access and Information Gathering

     Section 104 (e) of CERCLA clearly authorizes the Agency to
reguest information concerning the treatment, storage, disposal
or handling of. hazardous substances, and to enter premises
where hazardous substances were generated, stored, treated,
disposed, or transported.  This amendment would clarify and
confirm the President's right to access and information
concerning the release or threatened release of hazardous substances
by making explicit the original intent of. Congress when CEPCLA
was enacted in 1980.
                                              \
                                               *s
     Currently, there is no explicit authority to enforce
information reguests under CERCLA.  In addition, there is no
explicit language to compel parties to provide access to the
site or adjacent areas.  Access to the site is 'obviously
needed to conduct a response action.  The President may also
need access to adjacent  areas to conduct sampling or move -
     While landowners generally will provide access voluntarily,
explicit statutory authority would encourage private parties
to consent to access and information reguests, and would
provide explicit mechanisms for the President to obtain access
and information when such reauests are reasonable but refused.

     This amendment would also establish procedures for the
President to issue orders for access and information-  The
President would notify potential recioients of orders and
provide an opportunity for consultation.  The President could
also seek to have the Federal courts enjoin interference with
access and direct private parties to comply with orders.
This provision would enable the government to seek judicial
relief so that necessary response actions would not be unduly
delayed.

SECTION 204
     Administrative Orders for Section 104(b) Actions

     CERCLA section 104(b) currently authorizes the President
to conduct a- variety of investigations, studies, and information
gathering activities.  nnder this section, remedial investigations
and feasibility studies (BI/FSs) are performed to serve as the
basis for choosing the appropriate extent of remedy.
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      In some circumstances, it may he appropriate to allow
potentially responsible parties to conduct RT/FSs or other
investigations or studies.  This approach would free up
government resources to address other sites, and would
increase the likelihood that private parties would assume
responsibilities for cleanup of the site.  Such private-party
RI/FSs are most effective when they are performed pursuant
to an administrative order that clearly sets out the responsi-
bilities of the private parties.

     This amendment to CEPCLA would provide for administrative
orders on consent without the need for any findings by the
President with regard to potential hazard at the facility, to
allow the planning and investigative stages of response
actions to proceed more expeditiously.  The order would be
enforceable in district court, and the court could issue a
civil penalty for noncompliance.

     It should be noted that EPA retains the authority to
choose the appropriate remedy, based on a Record of Decision
developed by EPA.  This amendment would not authorize orders
on consent for actual cleanup activities under section 104.

     This section would also include a technical amendment to
section in? of CERCLA.  Section 107 currently provides for
treble damages from any person who is liable for a release or
threat of release and who fails without sufficient cause to
comply with an order under section 104.  The penalties established
for violations of administrative orders for access under
section 203 of this Act. and orders on consent for private
party studies and investiaations, are sufficient incentives
to assure compliance.  Accordingly, the reference to treble
damages for violations of section 104 orders would be removed.
This would not change the President's authority to seek treble
damages for violations of orders under section 106..

SECTION 205

     Non-Trust Fund and Pre-Trust Fund Expenditures

     This amendment would clarify and confirm that CERCLA
establishes liability for costs incurred by the United States in
response to a release or threatened release of a hazardous
substance from a treatment, storage or disposal facility
where the response was after passeae of the Resource Conservation
                               -40-

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 and  Recovery  Act  of  1976  and the  party knew  or should  have
 known  of  the  response  action.   Such  costs  must not  have  been
 inconsistent  with remedial  or  removal  actions  under CERCLA.

     The  United States has  incurred  substantial  response
 costs  in  connection  with  responses at  hazardous  waste  facilities
 occurring after enactment of RCRA that are wholly consistent
 with CERCLA's coals  and authorities.   Where  the  person knew or
 should have known of the  Federal  response  action, but  did not
 act  to clean  up the  release, it is entirely  appropriate  and
 consistent with CERCLA to clarify and  confirm  that  responsible
 parties are liable for such  response costs.

 SECTION 206

     Statute  of Limitations

     CERCLA currently  includes  no explicit statute  of
 limitations for the  filino of cost recovery  actions  under
 section 107.   Nevertheless,  the Federal government  recognizes
 the  need  for  filing  of  cost  recovery actions in  a timely
 fashion,  to assure that evidence  concernina  liability  and
 response  costs is  fresh,  to  help  replenish the Fund, and to
 provide some  measure of finality  to affected responsible
 parties.   The  absence  of  an  explicit statute of  limitations
 has  also  led  to some uncertainty  concernina  whether  the
 existence  of  such  a  statute  of  limitations should be assumed
 under  Federal  law.

     This  amendment  would eliminate this uncertainty by
 establishing  a six-year statute of limitations for  the filina
 of cost recovery actions.  The six-year statute  of  limitations
 is the  same as the period established  by a clear line  of
 cases  involving the  parallel provisions in section  311 of the
 Clean Water Act.  Because response actions may extend  for a
 number  of  years, the Government is not precluded from  commencing
 an action  for  recovery of costs at any time  after such costs
 have been  incurred.

     For purposes of this section, the response  action is
 regarded as comoleted unon completion of any ooeration and
maintenance activities funded by  the Federal government.

     In addition,  this amendment would provide a three-year
statute of limitations:  for damaae actions,  running from
the date of discovery of the loss; for contribution actions,
running from entry of iudament or the date of settlement;
and for rights subrooated pursuant to a claim paid from the
Fund, from the date of payment of such claim.
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SECTION

     Pre-Enforcement Peview

     The purpose of this amendment is to clarify the process
for judicial review of government decisions on the appropriate
extent of remedy and liability of responsible parties.  This
section establishes that:

     o  review of all Presidential decisions concerning
        remedy is on the administrative record;

     o  there is no pre-enforcement review of section 106
        administrative orders; and

     o  administrative orders are subject to iudicial review
        once response action is completed.

     (a)  Record Review:

     Wh.i3e CERCLA does not explicitly state how decisions on
remedies will be judicially reviewed, the Federal government
has taken the position and certain courts have suaqested that
review of decisions concerning remedy, like most administrative
decisions, are on the basis of the administrative record.
This amendment would clarify and confirm that judicial review
of the response action is limited to the administrative
record and that the action shall be upheld unless it is
arbitrary, capricious, or otherwise not in accordance with
law.  Reliance on an administrative record helps assure that
the basis for the response decision is clearly articulated
and open to the scrutiny by the public and responsible parties.

     Limiting judicial review of response actions to the
administrative record also expedites the process of review
and ensures that the reviewing court's attention is focused
on the information and criteria used in selecting the remedy.

     (b)  Pre-Enforcement Review:

     Section 106 orders may be subject to judicial  review at  the
time the government acts to enforce the order and collect penalties
for non-compliance.  This amendment would clarify and confirm
that orders are not subject to judicial review prior to  that
time.

       The clarification reflects the fact that pre-enforcement
review would be a significant obstacle to the use of administrative
orders.  It is likely that pre-enforcement review would  lead
to considerable delay in providing cleanups, increase response
costs and discouraae settlements and voluntary cleanups.
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      (c)   Review  of  Orders:

      The  chanaes  discussed  above  clarify  and  confirm  the
 existing  process.  Section  208(c)  would amend section lOfi  to
 establish new  procedures  for  reimbursement  of certain response
 costs and to provide for  judicial  review  of administrative
 orders once the response  action reauired  by the  order is
•completed.

      Under the amendment, responsible  parties can  reauest
 reimbursement  from the  Fund  for costs  incurred in  responding
 to  an order.   If  the President refuses to orant  all or part
 of  a  petition  for reimbursement,  responsible  parties  may
 file  an action in district  court  seekina  reimbursement.
 Responsible parties  can obtain reimbursement  if  they  can show
 that:

      o they are  not liable,  and  that  the costs  which they
        incurred  in  responding to  the  ord«r wsrs reasonable;  or

      o the response action  ordered  by the  President  was
        arbirtrary and  capricious  or otherwise not in accordance
        with law.

      This provision  is  intended to foster compliance  with  orders
 and expeditious cleanup,  allowing  potentially responsible
 parties to preserve  their positions  concerning liability and
 the appropriateness  of  the  response  action, in circumstances
 where they agree  to  undertake the  cleanup,  finder  the record  review
 provisions discussed above,  responsible parties  would also
 have  opportunities for  input into  the  decision making process
 for choosina the  appropriate response  action.

 SECTION 208

      Nationwide Service of  Process

      Rule 4(f) of the Federal Rules  of Civil  Procedure limits
 effective service of process to the  territorial  limits of  the
 State in  which the district  court  is held,  unless  a Federal
 statute provides  otherwise.'   niffaculties have arisen in
 obtaining personal jurisdiction over certain  defendants in
 actions by the United States under CERCLA.  This amendment
 would remove these difficulties by providing  that  the United
 States may serve  a defendant in any  district  where he resides,
 transacts business,  or  may  otherwise be  found.

 SECTION 209

      Abatement Action

      This amendment  would delete  the references  to "welfare"  in
 section 106 of CSRCLA.  Conseguently,  enforcement  or abatement
 action could only be taken  when the  President determines
 that  there may be an- imminent and substantial endangerment
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 to  the  public  health or  the environment because of an actual
 or  threatened  release of a hazardous substance from a facility.
 This  amendment  focuses CERCLA enforcement efforts on public
 health  and  the  environment.

 SECTION 210

      Federal Lien

      This amendment would enable the United States to recover
 at  least some of its response costs through an i_n rem action
 against the real property that  is the subject of the respons_e -
 action.  Such protection for the United States would also
 enable  it to recover the increase in land value resultino
 from  the response action, thus  oreventino unjust enrichment
 of  the  property owner.

      The amendment would provide that all costs and damages
 for which a person is liable to the United States under
 section 107(a)  shall be a lien  on all real property affected
 by  the  response action.  The lien would arise at the time the
 United  States first incurs response costs, but would not be
 perfected as against purchasers, security interest holders,
 and judament lien creditors (all as defined in the tax lien'
 statute, 26 U.S.C. $6321 et seof) until notice of the lien
 has been recorded or filed.  The notice provision would not apply
 with  respect to any person who  knew or should have known that
 the United States had incurred  response costs.

 SECTION  211

      Penalties

      This amendment would increase criminal penalties in
 section 103(d)(2) of CERCLA for destruction of records from
 .
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     This amendment provides procedures for administrative
settlement of CEPCLA claims.  The lanauaae is modeled closely
after a similar provision in the Federal Tort Claims Act, 10
U.S.C. S 2672.  Under the amendment, Federal aqencies are
authorized to settle claims for $25,000 or less in accordance
with Justice Department procedures, and to arrive at tentative
settlements for Justice Department approval for amounts over
$25,000.

SECTION 213

     Foreign Vessel Liability

     This amendment would delete from CFPCLA a clause that
had the unintended effect of excludina from liability under
section 107 all foreian vessels not under United States
jurisdiction, even when such vessels release hazardous
substances in areas otherwise subiect to United States
jurisdiction.
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 TITLE  III  —  AMENDMENTS  TO  THE  INTERNAL  PEVEMUF  COPE  OF  1954

     Title II of  CERCLA  amended  the  Internal  Revenue  Code  of
 1954,  establishing  the Hazardous  Substance  Response Trust
 Fund (Fund).   The Fund is comprised  primarily of revenue derived
 from excise taxes on  certain  petrochemicals and  inorganic  raw
•materials, as well  as on domestic crude  oil and  imported petroleum
 products  (87%)  and  appropriations from the  General Fund  (12%).
 Revenues  in the Fund  are used to  finance Superfund response and
 support activities.

     The  present  CEPCLA  tax scheme is referred to as  a  "fee3-
 stock  tax" because  it imposes a  tax  on-the  basic chemical
 building  blocks of  chemical products.  The  hazardous  substances
 and wastes associated with  the  problems  addressed by  CEPCLA are
 byproducts of production processes that  use these raw materials.

     The  Fund was designed  to contain aporoximately  SI.6 billion
 from FY 1981  through  FY  1985.  Current authorization  to  impose
 taxes  to  finance  the  prooram  expires September 30, 1985.  This
 amendment is  needed to authorize  the imposition  of taxes to
 finance Superfund response  actions over  the next five years.

     The  tax  structure set  forth  in  these amendments  has been
 designed  to meet  the  following  objectives:

      0 to provide  a  stable and  predictable source of revenue;

      0 to broaden  the tax  base from which  contributions are
        received;

      0 to minimize adverse economic imoacts  on  taxed -industries;
        and

      0 to focus the  tax on the type of  industries  and  practices
         that have caused the  problems  that  are addressed by
        Superfund.

      The  amendment  would authorize a Fund of  aooroximately
 SI billion per year,  or  roughly S5.3 billion  from FY 19-86  through
 FY 1990.   This represents  the level of  funding that  can be
 effectively managed over the  next five  years  and raised without
 sianificant adverse affects on  tax paying firms.

      The  amendment  would establish a Fund with revenue derived
 primarily from three sources.

      The  first source of revenue would  be derived from a
 feedstock tax.  This tax would  be imoosed on  crude oil and
 petroleum products  as well  as the 42 chemical feedstocks
 taxed  under the present  statute.  The  tax rates  imposed on
 these  feedstocks would  remain the same  as the rates estab-
 lished in 1980: approximately S4.87 per ton for petrochemical
 feedstocks, approximately  S4.45 per ton for inorganic raw


                                 -46-

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materials  {with  adjustnents  for  elemental eouivalency),  and
0.79  cents  per barrel  for  crude  oil  and oetroleum oroducts.
This  feedstock tax  would maintain  the current CEP.CLA exemptions
on methane  or butane used  as  fuel, substances used  in  the
production  of fertilizers, sulfuric  acid produced as a  by-
product  of  air pollution control,  substances derived from
coal,  and  taxable chemicals made from previously taxed  taxable
•chemicals.  The  feedstock  tax has  been desianed to  raise
approximately $300  million oer year.

       The  second source of revenue would be derived from a.
waste-management tax.  This  tax  would be imposed on the
receipt  of  hazardous wastes  at a Qualified treatment,  storage,
or disposal unit (i.e. a unit permitted under the Resource
Conservation and Recovery  Act (RCRA)), as well as on hazardous
wastes disposed  of  in  the  ocean  or exported from the United
States.  The tax liability would be  imposed on the  owner or
operator of a qualified hazardous  waste management  facility,
the owner  or operator  of a vessel  that disposes of  wastes
into  or  over the ocean, and  the  exporter of hazardous  wastes.

      The tax rates  imposed under the waste-management  tax
would increase each year of  the  tax, and would be hiaher for
landfills,  surface  impoundments, waste piles, and land treatment
units.  The followina  amount per wet^weiqht ton would  be imposed;
      Year         Pate *

      FY 86        S 9,80 per ton
      FY 87        $10.09
      FY 88        S11.13
      FY 89        S13.48
      FY 90        S16.32

      For waste exoorted from the U.S.,  disposed into or over
 the ocean, or received at a Qualified hazardous waste manage-
 ment unit other than specified above, the following amount
 per wet-weight ton would be imposed:

      Year         Rate *

      FY 86        S 2.61 per ton
      FY 87        S 2.68
      FY 88        S 2.96
      FY 89        S 3.59
      FY 90        S 4,37
    * Beginning in 1*87, the tax rates would be adjusted annually to
 compensate for any shortfalls in projected revenues.  If necessarv
 to meet revenue targets, the tax may be extended from October 1,
 1990, through March 31, 19*1, at the same rates applicable in
 Fiscal Year 199O.
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     Bastes manaqed in units not subject to permits under
subtitle r of RCRA (e.a. wastes stored In tanks and containers
for less than 90 days), wastes from CERCLA response actions, and
wastes oenerated bv federal facilities would not be subject to
the waste-nanaaenent tax.  Additionally, a credit would be
given for taxes already paid on wastes that are transferred
from one taxable unit to another.  If the units involved in
the transfer have different applicable tax rates, the credit
would be based on the lower rate.

     The w-aste-manaoement tax has been desianed to-raise approx-
imately $600 million per year.                 -   •

     The third source of revenue would .be derived from interest
on Superfund investments, fines, costs recovered from parties
responsible for response actions financed from the Fund, and
intra-fund transfers.  This portion of the Fund would raise
approximately S100 million per year.
                                 -48-

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TITLE IV — MISCELLANEOUS PROVISIONS
SECTION 401

     Applicability of Amendments

     This amendment would add a new section to CERCLA providing
that the amendments relating to section 104(a) and 
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                  STATEMENT OF LEE M. THOMAS
                        ADMINISTRATOR
             U.S. ENVIRONMENTAL PROTECTION AGENCY
                          BEFORE THE
                     COMMITTEE ON FINANCE
                     UNITED STATES SENATE

                        APRIL 25, 1985


     Mr. Chairman and members of the Committee.  It is a

pleasure to be here today to talk about the Administration's

proposal to reauthorize the Comprehensive Environmental

Response, Compensation, and Liability Act — the Superfund.

In particular, I want to lay out for you a complete rationale

for the cost and revenue projections supporting our proposed

funding level and mention our proposed financing provisions.

     As you know, on a number of occasions I have expressed

concerns about the size and scope of some of the reauthorization

options considered by Congress.  Historically, there has been

a tendency on the. part of the Federal government, whenever it

deals with a major national problem, to' equate total funding

with the effectiveness of a particular solution.  The more we

spend, the more we must be doing,  or so that philosophy goes.

     With Superfund, this is not the case.  We are faced

with a national challenge that is enormous in scope and

implication.  But during the past two years, we have worked hard

to fashion a program capable of dealing with both the immediate

and the long-term consequences of the hazardous waste problem.

It is essential, as we prepare to extend that effort, to make

sure we stay on course with a program which has been proven

effective.
                                 -50-

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     I am convinced that the Administration's Superfund
reauthorization bill is a sound and responsible approach for
implementing our hazardous waste cleanup program for the
next five years.  It triples resources available for actual
cleanup work.  It focuses those resources on the-most serious
problems first — uncontrolled and abandoned hazardous substance
sites.  And it strengthens our ability to enforce the law
and impose stringent new penalties on those who violate it.
     In short, the bill gives EPA the resources and the
authorities we need to continue to build on the cleanup
momentum established during the past two years.  The President
told me to make Superfund my top legislative priority for
1985, and I have.  I will work with you to assure that the
Superfund program is allowed to continue with its vital
mission.
     As I said, our proposal will substantially increase the
size of the fund.  It will generate some $5.3 billion during
the next five years, principally from taxes on those industries
linked directly to the nation's hazardous waste problems.
Coupled with an aggressive enforcement program which we
project will yield an additional $2 billion  in private-party
cleanup, we anticipate a program likely to generate approximately
$7.5 billion in total cleanup activity between 1986 and  1990.
                               -51-

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      With this resource base,  we will be able to expand our
 emergency cleanup program for  addressing immediate threats
 to human health and the environment.   In the long-term arena,
 we will  work toward permanent  solutions to chronic hazards.
 And we will  guarantee  that affected communities and individual
 citizens have a meaningful role to play in all of our cleanup
 activities.
      My  purpose today  is not to address the details of the
 Administration's proposal, although I am happy to answer any
 questions you may have.  Rather,  I would like to spend my
 time  here talking through with you why I feel this bill
 provides us  with all the resources we can use during the next
 five  years.   I want to  explain where  we see the funding coming
 from, and what we expect to be buying in the way of cleanup.
      It  is ray hope that we will conclude today's hearing with
 a  better understanding  of the  Administration's package, the
 rationale for those options we have selected in crafting it,
 the complexity of the Superfund program as  it moves into high
gear, and the reasons why this bill represents our best bet
 for moving forward with the second phase of this national
priority program.
     Putting  together the  reauthorization package has been a
difficult  challenge.  The  original Superfund law was sweeping
in nature  and  scope.  But  it was designed to address a problem
of unclear magnitude, in  the absence  of any first-hand
experience.
                                  -52-

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      Today,  we  have  that  experience.   Superfund  reflects  over
 four  years of experience.   We  have  a  far  better  appreciation
 for the  complexity of  the  problem we  face,  and for  its  enormity,
 We  have  our  feet  on  the ground and  we are making progress.
      We  have in place  an  effective  program  for identifying
 potentially  hazardous  sites, evaluating them, assessing the
 risks posed  by  each, and  selecting  those  requiring  Federal- -
 attention.   More  than  800  sites are now on  our National
 Priorities List.  As many  as 2,000  sites  — perhaps more  —
 will  eventually be identified  as most in  need of long-term
 cleanup, often  using Federal resources.
      But the Superfund law does more.  It also gives us tools
 for protecting  human health and the environment  from immediate
 dangers caused  by unexpected releases of  hazardous substances.
 Under this emergency cleanup authority we can take a variety
 of steps to  address immediate  dangers at  any site.
      It is these two primary authorities  — long-term authority
 to clean up  sites posing chronic threats  and emergency
 authority to eliminate immediate hazards  — that  are the
 framework within which we  plan  for  the future.
      Based on projections  for  how many new  long-  and short-term
 activities we will start each  year, historic data on how  long
 it takes to conduct various cleanup steps,  and experience
with costs, we are able to put  forward what we feel are
reliable estimates of our  needs over  the  next five years -
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     Long-term cleanup work at national priority sites has three
distinct phases.  First, there is the planning phase during which
engineers and other technical professionals carefully characterize
the site and assess the feasibility of cleanup options. Second,
once we decide on a cleanup strategy, we design the remedy.
Finally, we actually implement the remedy.   This is generally
a complex construction project.
     Typically, it takes about 18 months to carry out the
first step.  Our remedial investigations and feasibility
studies look at all site factors, including geological structure,
soil characteristics, mixes and concentrations of contaminants,
and hydrogeology.  With this information, we determine the
extent of the problem, including whether groundwater has been
                                                               •
contaminated.
     We spend on average about $800,000 for each of these
comprehensive studies.  But without them, it is impossible
to undertake an effective cleanup.  Every Superfund site is
unique.  There is no generic cleanup strategy*  A complete
remedial plan must be developed for each.  The Federal government
pays for 100% of the cost of these studies.
     On the basis of the information we gather, we make our
cleanup decisions.  Because each site  is unique, each  remedy
requires its own special design.  Each is a detailed engineering
blueprint.  Each takes about nine months to complete at a  cost
of $440f000.  The Federal government picks up  the entire cost.
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     Construction of the remedy is the most costly portion of
the cleanup process.  Our experiences to date indicate the
design and construction of an individual remedy costs about
$7.2 million.  The Federal government pays for 90% of this
cost, with the State picking up the remaining 10%.  Construction
can take a year to complete.
     Once a site has been cleaned up, we conduct operations
and maintenance activities to make certain the remedy is
effective.  The Federal government pays for 90% of these
costs for the first year, and the State pays the remaining
10%.  Thereafter, the State picks up all O&M costs.
     Sometimes, sites pose an immediate threat to human health
or the environment.  In these cases, there is no time to
conduct a comprehensive study.
     If the responsible parties do not act, or cannot, we
must be able right away to address known explosion hazards,
threats of human contact, or the possibility of fire.  We do
this using our emergency response authority.
     A typical removal action takes  from one to six months
to complete, depending on the individual characteristics  of
the site.  Some have cost in excess  of $1 million, but the
average cost is $330,000.  When the  government conducts an
emergency cleanup, the entire cost is borne by EPA.
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      Using the numbers I  have  just reviewed,  all  based  upon
 over four years of  first-hand  experience,  we  have been  able
 to project our resource needs  during  the next five years.
 Several  important assumptions  are  built  into  these estimates:
      o The Federal  program will  start engineering feasibility
 studies  at 130 new  sites  annually.
      o Responsible  parties will  undertake  a gradually increasing
 number of new starts  each year,  beginning  with  50 in 1986  and
 growing  to 90 in 1990.
      o There  will be  238  emergency cleanups annually, including
 190  by the Federal  program and 48  by  responsible  parties.
      Because  each step in the  cleanup process —  studies,
 design,  construction,  and O&M  — takes a different amount  of
 time, the  overall program operates  like a  pipeline.  Thus,
 while we  start roughly the same  number of  new sites each
 year, over time  we  find ourselves managing an ever-increasing
 total number  of  sites  in  various stages of cleanup,
 simultaneously.
     This  is  a critical concept  in  understanding  the limitations
 I  see on  how  fast we can  clean up our priority  sites.   It  is
 a  complex  management problem.  My concern  is  that we will
 allow ourselves  to  think  that  the more money  we spend in a
given year, the more cleanup we  will  accomplish.
     I am  convinced that  there is a practical limit to  the
number of  sites we  can deal with at one time.   And  I am
convinced  that we are  rapidly  approaching  that  saturation
point.
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      Allow me  to demonstrate  the  pipeline  effect  I  have  just
 described.   Our projections  show  that  the  number  of new  starts
 annually will  increase  very  slowly,  due  entirely  to a  gradually
 increasing number of  private  party cleanups.   Yet between
 1986  and 1990,  the number  of  sites with  remedial  activity
 underway will  grow dramatically.
      In  1986,  we expect to start "180 new engineering feasibility
 studies,  including 50 by responsible parties.   That's  the
 front-end of the pipeline.  But on-going work  at  other sites
 means  we  will  actually  be  managing 584 long-term  sites at
 the close of that year.  By 1988,  we expect to start 200 new
 planning  studies,  including 70 by  responsible  parties.  Yet,
 because  of  the  pipeline  effect of  on-going work,  we  will be
 managing  726 remedial sites in various stages  of  cleanup.
     And, by 1990,  we will see 220 new starts,  including 90
 by responsible  parties.  But  we will be  managing  a  total of
 811 long-term sites, each  with unique circumstances.
     And  don't  forget,  we  expect to be involved with 238
 emergency cleanups  in each of those years on top  of  our
 remedial  projects.  So by  1990, we will  be dealing  with well
 over 1,000  sites,  all at the -same  time.
     I say  to you  without  any reservation, this is  the ultimate
management  challenge.  The American people have very high
 expectations from  the Superfund program.  I am committed to
 fulfilling  their  reasonable expectations.  I fear that a program
 any larger  than  the one  I  have just outlined could  collapse of its
own weight.  The  resulting waste and fraud would  be  devastating.
                                -57-

-------
     Congress and the American people must recognize the many
constraints that we are dealing with in trying to implement
Superfund.  This is a multi-billion dollar program.  The
sheer size of the fund makes it a prime candidate for abuse.
I will do all I can to prevent this through rigid systems of
accountability.  I ask your help in allowing me to retain the
flexibility I need to succeed.
     In addition, we face several other constraints:
     o Technical Constraints: Depending on the iev«i oŁ
cleanup required by a reauthorized Superfund law and any
prohibitions against off-site remedies, landfill capacity
will be a critical issue in the years ahead.  Presently, there
are few double-lined facilities which can accept waste.  There
may be regional shortfalls, at times caused by transportation
problems.
     o Permanent Solution Constraints: No one wants wastes  from
one Superfund site to contribute to the problems of future
priority sites.  There are some promising technologies on
the horizon that provide alternatives to land disposal, such
as incineration and chemical and biological stabilization.
Although some are proven feasible, their commercial availability
remains limited.  As demand for these technologies  increases,
we are hopeful available capacities will grow.
     o Laboratory Capacity Constraints: Current national
laboratory capacity is short of our needs.  We are  working
to improve the reliability and responsivness of our contract
labs, but problems remain.
                                -58-

-------
     o Managerial Constraints: As I have already suggested,
we face an enormous management challenge during the next five
years of Superfund.  The pace at which the program is expanding,
particularly as more and more sites move through the pipeline
to the expensive design and construction phases, makes
effective management difficult.  In addition to overseeing
the complex work at hundreds of sites, we must recruit and
train professional staff, provide adequate workspace, obtain
and maintain necessary equipment, provide administrative and
logistical support, and establish the contract capacity needed
to handle the additional workload.
     o Personnel Constraints: In particular, we face a
difficult challenge in finding, hiring and retaining people
capable of carrying this program out.  We are competing with
the private sector for specialized talent.  Often, we simply
cannot offer the compensation, working environment and
incentives that the private sector can for these individuals.
Yet our engineers must oversee the work of theirs.  Our
managers must supervise the technical and administrative
activities associated with hundreds of projects.  And our
attorneys must go head to head with the best lawyers the
private sector has to offer in multi-million dollar litigation.
     Let me stress at this point that I am not painting a
picture of gloom and despair.  We have, during the past four
years, built a very effective cadre of managers, technical
people, scientists, engineers and lawyers.  But we must
continue to build our team while, at the same time, working
to retain the excellent people we already have.
                               -59-

-------
      In this area of people, we find the Federal system is
one major  impediment to faster expansion of our technical
capabilities.   It takes an average of four months to bring on
an entry-level  hydrogeologist, chemist or environmental
scientist.  These people, despite their qualifications,
require a  period of time for training to understand the
program, the Federal system, and their roles in it.
      At the senior level, the problems are even greater.  We
face  the same rigid recruitment system.  And there are not
enough well trained people with experience in hazardous
waste cleanup.  The private sector is a fierce competitor for
these talented men and women.  Many times, we are simply
priced out of the market.
     Let me recap, then, my concern over the expectations
I think exist among many members of Congress and a large
segment of the American people who think getting-the cleanup
job done faster is nothing more than a matter of dollars.
It isn't.
     In 1990 alone, we will have work underway at more than
1,000 long- and short-term sites.  That's a management
challenge.
     At every site, we face difficult technical problems,
laboratory constraints, and the prospects of disposal capacity
shortfalls.  Those are management challenges.
     And we are engaged in fierce competition with the private
sector for talented, well-trained professionals needed to
make this program work.  That's a management challenge.
                                -60-

-------
      The program we have put  forward  in  the  form of  S.494,
 the Administration's proposal  to  reauthorize Superfund  through
 1990/  is a blueprint for achieving  significant cleanup  in
 light  of all of these constraints.  It is carefully  thought
 out and based on first-hand experience.  It will buy a
 substantial amount of cleanup.  It  will give us powerful
 tools  to foster a significant  chunk of private-party cleanup
 in addition.
      Our bill will yield some  $7.5  billion worth of  cleanup
 through 1990, including $5.3 billion  in Federally financed
 work and another $2 billion or so in  private-party cleanup.
 These resources will purchase  impressive amounts of  cleanup.
 By 1990, we project that we will have undertaken 1,450
'engineering feasibility studies, about 1,000 designs, and
 approximately 900 construction projects.  Remedial work
 will be completed at well over 600 sites.  In addition, we
 e-xpect to have conducted nearly 1,900 emergency cleanups.
      We will  not be finished with the Superfund mission
 by 1990.  But we will  have made a significant dent in the
 problem.  We  will be well on our way to achieving one of the
 most ambitious environmental goals ever set.
      The next question  that comes to mind is where will we
 get the $5.3  billion needed to make this program work?  The
 Administration  is  convinced these  funds can be  raised in a
 way that is fair and equitable, without having  any impact on
 the national  deficit.
                                 -61-

-------
     We nave proposed a prograir. financed largely through
taxes on. petrochemical feedstocks and hazardous wastes
generated in the manufacturing process.  other important
components in our financing scheme are interest on Fund
investments and recoveries of past Fund expenditures from
responsible parties.
     Our current feedstock tax would continue without change.
We have found it to be a reliable source of significant funds,
yet one that has not hurt the competitiveness of our chemical
producers.  We are concerned, however, that an expansion of
this particular tax could do harm to the chemical industry.
     The waste-end tax we have proposed will generate some $600
million annually in new revenues.  Its design reflects our
belief that those companies generating hazardous wastes, and
profiting from the activities that yielded those wastes, are
logical candidates to help finance our expanded cleanup program,
     Although the same companies that pay the feedstock tax
will also contribute through the waste-end mechanism, this
taxing scheme will also bring into the system thousands of
other companies that have not paid their fair share  in  the
past.  We think this adds some needed  equity to our  effort  to
raise the substantial funds required  to finance the  next  five
years of cleanup.
     We are convinced that there  is no need  to  tap general
revenues  to fund Superfund.  These taxes, plus  interest and
recovered costs, will provide us  with the revenues we need to
succeed.
                               -62-

-------
     Let's look quickly at the cost-recovery element of our
financing equation.  We expect, over the next several years,
to see cost recovery become a major source of cleanup funds.
There has been some concern to date over the slow pace of
cost recovery.
     Much of the explanation is related to the fact that
cost-recovery cases cannot be initiated until- much of the
cleanup work has been completed.  And, as we all know, it
has only been in the past two years or so that the actual
pace of cleanup has picked up.
     Costs recovered to date total nearly $12 million.  But
we have initiated cost-recovery actions in cases worth more
than $124 million.  Just as the number of sites cleaned up
will depend upon the remedial pipeline I discussed earlier,
so too will the pace of cost recovery.
     As a rule of thumb, cost recovery takes two to three
years to complete for each site.  In cases where we have
conducted a removal action, cost recovery is initiated within
one year after the emergency action is completed.  Funds are
not likely to be recovered, however, until about two and one-
half years after completion of the removal.
     In cases of long-term cleanup, cost recovery is initiated
during the construction phase.  But we do not expect to actually
recover our funds until about two years after construction
has been completed.
                                -63-

-------
     Now that we have a significant number of projects well
into the cleanup process, we are beginning to take more and
more responsible parties to the courthouse to recover our
expenditures.  Our earlier investments should pay off in the
next five years.
     In 1986, we expect to receive nearly $32 million in
recovered costs.  That will increase to nearly $55 million in
1987, and grow to $190 million in 1990.  The total of recovered
costs from 1986 through 1990 is expected to be $477 million.
This will be a significant supplement to our tax revenues.
     Finally, we anticipate that our aggressive enforcement
program will yield some $2 billion in actual cleanup work by
responsible parties through 1990.  These will be funds from
private sources, not out of Superfund.
     Our record of private-party cleanup settlements has been
an impressive one during the past two years.  By effectively
using the current enforcement tools, including strict, joint and
several liability, we have been able to convince more and more
responsible parties that it is in everyone's best interest to
reach an acceptable settlement and get on with cleanup.
     Through 1990, we project that responsible parties will
complete more than $2 billion worth of cleanup.  During that
same period of time, we anticipate that the value of cleanup
started by responsible parties will approach $3 billion.
                              -64-

-------
      Let  me  conclude  now by restating  what  I  have  been  saying
 for  a long  time.   Superfund is  a  vital program.   It  is  one  of
 EPA's top priorities.   Reauthorization of Superfund  is  our
 number one  legislative  goal.
      During  the past  two years, we  have put Superfund
 implementation on  a sound footing.   The program  has  expanded
 dramatically.  We  are seeing  important results.   It  is
 absolutely essential  that Superfund be reauthorized  this  year
 in order  to  keep our  cleanup  efforts moving at the pace we
 have  established.
      I  am convinced that we are approaching the  point where
 Superfund is operating  at an  optimum level.   By  the  end of
 1990,  under our proposal,  we.  will be working  at  more than
 1,000  long- and short-term sites.   Beyond this level of
 activity, there is a very real possibility  that  the  program
 could  begin to lose the  management  accountability  that  we
 have  worked so hard to  establish.   The last thing  we need is
 for Superfund to become  tainted by  charges  of mismanagement,
 waste,  fraud and abuse.
      In addition to my  concern that if we go  past  the
 Administration's proposed  funding level we  will  do nothing
more  than throw money at  the  problem,  I have  also  tried to
 lay out before this Committee the managerial, technical and
 administrative constraints  that do  in  fact  affect  our program.
     Our  proposal  is a  sound  one, based on  first-hand
experience and a recognition  of the complexity of  our mission.
 I urge you to adopt it.    Thank you  for allowing  me to be  here
today.  I would be happy  to answer  your questions.
                              -65-

-------
THE FOLLOWING SECTION IS A LIST OF
COMPLETED SUPERFUND EMERGENCY ACTIONS
FROM DECEMBER 1980 THROUGH MAY 30, 1985
               -67-

-------
SUMMARY: CASES  FILED AND SETTLEMENTS,  December  1980—MAY  30,  1985


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COMPLETED  SUPERFUND EMERGENCY  ACTIONS,  December 1980—May 1985-
                            BNB
                                                                              LOCATION
                                                                                                        NPL
                       •0/12/00
                       •2/01/21
                       •2/03/00
                       •2/07/00
                       •2/Ot/OO
                       •2/10/23
                       •1/01/23
                       •3/04/07
                       •3/03/12
                       •3/07/01
                       •3/M/OJ
                       •3/M/ll
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                       •3/10/13
                       •3/10/21
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                       •4/01/27
                       •4/03/23
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                                                            -68-

-------
REGION
                                            BANE
                                                                           LOCATION
                                                                                               STATE
                                                                                                        NPL
03
             14/10/31
             •4/11/01
             I4/M/2*
             •4/12/01
             •4/12/13
             •4/12/1*
             •4/12/20
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  •2/04/24
  •2/01/09
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  •2/10/12
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                                              -69-

-------
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                 EXO
                                            RAME
                                                                          LOCATIOft
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-------
UC1M
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10
•2/04/03
•2/03/00
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•3/07/01
•3/09/22
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•4/07/01
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-------

-------
THE FOLLOWING SECTION INCLUDES LETTERS
SENT BY THE ADMINISTRATOR OF EPA TO
SENATOR ROBERT STAFFORD AND CONGRESSMAN
JOHN DINGELL EXPLAINING SHORT-TERM MEASURES
UNDERTAKEN TO KEEP THE 3UPERFUND OPERATIONAL
IN THE EVENT CERCLA TAXING AUTHORITY IS
NOT REAUTHORIZED BEFORE IT EXPIRES ON
SEPTEMBER 30, 1985.
                  -99-

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              SUPERFUND CONTINGENCY PLAN SITE LIST

                           FACT SHEET
     Taxing authority under the Comprehensive Environmental
Response, Compensation, and Liability Act (Superfund) will
expire September 30, 1985, if not renewed by Congress.  The
revenue generated by this act is used to fund cleanup activities
at  abandoned and uncontrolled hazardous waste sites.
     In identical letters to Senator Robert Stafford (R-VT) a'nd
Representative John Dingell (D-MI) August 1, and in follow-up
letters on August 16, EPA Administrator Lee M.  Thomas expressed
his concern that Congress may not complete reauthorization of
the Superfund law before the September 30 deadline.  He explained
that he would soon be forced to slow down cleanup activities
pending Congressional action.


     By delaying new obligations- at sites as of August 14,
thereby halting work temporarily, the agency hopes to minimize
long-term damage to the program.


     Through these actions, the agency will accumulate funds
sufficient to enter fiscal year 1986 with critical functions,
such as site identification and investigation,  emergency response
capabilities and enforcement activity, intact.   We will continue
to take whatever actions necessary at any site to assure
protection of public health.


     A list of 67 projects at 57 sites where work will be
immediately slowed or halted pending final action by Congress
is attached.  This list represents approximately $125 million
in new funds through September 30, 1985.


     It is important to note that the Superfund slowdown is
temporary.  Work will resume as soon as the Act has been
reauthorized and an appropriation backed by a long-term funding
source is in place.
                              -100-

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  3f   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                    WASHINGTON DC  20460

                      August 1, 198r
                                           THE ADMINISTRATOR
Honorable Robert T. Stafford
Chairman
Committee on Environment
 and Public Works
United States Senate
Washington, D.C. 20510

Dear Mr. Chairman:

     This is in response to a question you posed to Or. J.
Winston Porter during his confirmation hearing before your
committee July 24.  It concerns the  funding required to run
an enforcement-only Superfund program.  Additionally, I have
been asked by Congressman John Dingell, Chairman of the House
Committee on Energy and Commerce,  to explain the impact on
the program should the Congress fail to reauthorize Superfund
at all, or for only a limited period of time.  This letter
addresses each of these concerns.

     Superfund must remain a total program.  Enforcement
alone is not enough.  To succeed,  we must have an effective
emergency response program capable of addressing immediate
hazards to public health and the environment.  We must have
adequate funding to assure cleanup of those sites posing
long-term threats.  Use of these two cleanup authorities
whenever necessary is the foundation for an effective
enforcement program.  Without them,  our enforcement presence
will be drastically diminished.

     I am gravely concerned about  the future of the Superfund
program.  Failure to pass a five-year reauthorization similar
to the proposal offered by the Administration in January,
prior to the expiration of the existing taxing provision on
September 30, 1985, will cause tremedous disruption in the
program within a short period of time.  Stop-gap funding
measures or a one-year reauthorization will cripple the
momentum we have established during  the past two and one-half
years.
                            -101-

-------
     During -the past five years,  we  have  worked  hard  to
develop an effective cleanup program capable  of  responding  to
both emergency situations and chronic hazards.   Because
cleanup of national priority sites takes  several years to
complete, we have established a pipeline  of major projects  in
various stages of development.  The  pipeline  is  now full.  Some
projects are in the engineering phase.'  At others, we have
chosen and are designing a remedy.  At still  others,  actual
construction is underway.

     It is critical that we have ah  assured source of funds
during the next five years to guarantee that  this cleanup
momentum continues.  Without it, the pipeline will slow to a
trickle.  Long-term cleanup of major sites  requires long-term
planning and assured funding.

     The consequences of a failure to pass  a  five-year
reauthorization of Superfund will be readily  apparent.
Damage to the program will be almost immediately disruptive
and potentially long-lasting.  Yet these are  the prospects
we face.

     Given the current status of Superfund on Capitol Hill,
and the possibility that  it will not be reauthorized  by
September 30, I am confronted with limited choices.   I can
continue to operate the program assuming that it  will be
extended in a timely fashion.  Or, I can ease the program
into a slowdown  in hopes  of minimizing the damage.   The
consequences of playing brinkmanship are unacceptable to
me.  I feel I must choose the  latter option.

     During the  next several  weeks,  I will begin  to  implement
a slowdown of the cleanup program.   We face  the bleak prospect
of slowing or halting cleanup work  at many sites  nationwide.
My staff  is currently compiling a list of sites which are  now
in the pipeline  awaiting  normal contractual  commitments.
These are  the sites where work will  cease first.   As we  move
into fiscal year 1986, more  sites will be affected.   Once  the
list is  completed,  I will provide you  with a copy.

     In  addition,  I will  place a  moratorium  on  new hiring  for
Superfund,  reduce  our support contracts, and limit all other
work not directly  related to emergency response activities.
                           -102-

-------
     These actions are dramatic.  Yet it is necessary to
ensure that there will be sufficient funds remaining to
carry on critical functions as we enter fiscal year 1986.
We must keep our emergency response capability intact.  We
must also maintain the cadre of experienced and dedicated
professionals that are the very heart of our Superfund program.
It has taken years to develop an infrastructure of trained
staff, reliable contractors, and adequate laboratory services.
We now have an effective relationship with state agencies
as well as the public's trust in our ability to get the
job done.

     As you requested, I am enclosing an analysis of the
costs to run the Superfund enforcement-only program.  I have
also included my project-ion of additional resources needed
to fund a continued emergency cleanup program as part of a
plan to phase down the rest of the Superfund effort.  I
emphasize, however, this is not a solution to the Superfund
reauthorization problem.

     Superfund is not a short-term program that lends itself
to short-term fixes.  It is a long-term program that must
have a long-term funding commitment.  A one-year reauthorization
is not good enough for Superfund.  The continuity of  a  fiver
year reauthorization  is essential.

     The nation has made a  tremendous emotional and  financial
investment in Superfund.  One that must be respected.   I  urge
you to work with your colleagues in  the Senate and  the  House
to complete reauthorization of  this  vital program as  soon  as
possible.
                          -103-

-------
         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON. D.C. 20460


                            *&  16/965

                                              THE ADMINISTRATOR

 Honorable  Robert T,  Stafford
 Chairman
 Committee  on Environment                                        _ -
   and  Public Works
 United States Senate
 Washington,  D. C. 20510

 Dear Senator Stafford:

     In my August 1  letter  to you, I stated my concern that work
 on reauthorization of the Comprehensive Environmental Response,
 Compensation,  and Liability Act  (Superfund) would not be completed
 by September 30,  1985.  As  you are aware, on that date our authority
 to collect taxes  that fund  cleanup activities at abandoned and
 uncontrolled hazardous  waste sites will expire.

     Because of  this uncertainty, on August 14 I began to slow
 down or halt work at sites  where we were scheduled to obligate
 funds  before September  30 of this year.  I must take this action
 to conserve  all  available funds for continuation of essential
 operations such  as site identification and investigation, emergency
 response actions  and enforcement activities.

     As I  indicated  in  my earlier letter, I am now providing a
 list of 67 sites  where  long-term work is underway and obligation
 of  funding for new activity will be delayed.  These sites,
 scheduled  to receive new funding after August 14, represent
 approximately $125 million  in cleanup activity. These obligations
 must be delayed  in order to keep sufficient funds in reserve to
 continue essential activities beyond September 30.

     I  stress that the  decisions I am forced to make now are
 short-term steps  necessary  to keep the program operational beyond
 September  30 of this year.  Work will resume at these sites once
 an  appropriation  backed by  an assured long-term funding source
 is  in place. We will continue to take whatever actions are
 necessary  at any  site to protect the public health.

     My staff and I  stand ready to assist you as you continue to
work to expedite  the reauthorization process.


                               fi   Sincerely,


                            ^L*^ V
                               ^   Lee H. Thomas


                            -104-

-------
                            SUPERFUND CONTINGENCY PLAN
                                    SITE LIST
 EPA REGION I
 Site Nane                                                      Stagea

 Charles-George Reclamation Trust                                  RA
   Landfill,  Tyngsbourough, MA
 Groveland, Groveland, MA                                          RD
 Hoconoco Pond,  Westhorough, MA                                    RD
 Nyanza Chemical Waste Dump, Ashland, MA                           RD
 Nyanza Chemical Waste Dump, Ashland, MA                           RA
 Beacon Heights Landfill, Beacon Falls, CT                         RD
 McKin Co., Gray, ME                                               RA
 Picillo Farm,  Coventry, RI                                        RD
EPA REGION II

Site Name                                                     Stagea

Bog Creek Farm, Howell Township, NJ                               RD
Bridgeport Rental & Oil Services, Bridgeport, NJ                  IRM
Bridgeport Rental & Oil Services, Bridgeport, NJ                  RA
Burnt Fly Bog, Marlboro Township, NJ                              RD
D'Imperio Property, Hamilton Township, NJ                     .    RA
GEMS Landfill, Gloucester Township, NJ                            RD
GEMS Landfill, Gloucester Township, NJ                            IRM
Glen Ridge Radium Site, Glen Ridge, NJ                            RD
Goose Farm, Plumstead Township, NJ                                RD
Helen Kramer Landfill, Mantua Township, NJ                        RD
Lipari Landfill, Pitman, NJ                                       RD
Montclair/West Orange Radium Site, Montclair/West Orange,  NJ      RD
Swope Oil & Chemical Co., Pennsauken, NJ                          RD
Marathon Battery Corp., Cold Springs, NY                          RD
Clean Well Fields, Clean, NY                                      RD
Sinclair Refinery, Wellsville, NY                                 RD
Sinclair Refinery, Wellsville, NY                                 IRM
Wide Beach Development, Brant, NY                                 RD
York Oil Co., Moira, NY                                           RD
EPA REGION III

Site Nane                                                       Stage3

Douglassville Disposal, Douglassville, PA                        RD
Drake Chemical, Lock Haven, PA                                   RD
Lackawanna Refuse, Old Forge Borough, PA                         RA
Lansdowne Radiation Site, Lansdowne,  PA                          RD
Moyers Landfill, Eagleville, PA                                  RD
Tysons Dump, Upper Merion, PA                                    RA
Sand, Gravel & Stone, Elkton, MD                                 RD
                                  -lub-

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8/14/85
                          SUPERFUND CONTINGENCY PLAN
                                   SITE LIST
EPA REGION IV

Site Name                                                       stage8

Davie Landfill, Davie,  PL                                         RD
Miani Drum Services, Miani,  FL                                    RD


EPA REGION V

Site Name                                                       Stage3

Acme Solvent, Marxist own, IL                                      RD
Byron Salvage Jfard, Byron, IL                                     RA
Outboard Marine Corp. ,Waukegan,  IL                                RD
Wauconda Sand & Gravel, Wauconda,  IL                              RD
Charlevoix Municipal Nell, Charlevoix, MI                          RD
Charlevoix Municipal Well, Charlevoix, MI                          RA
Northemaire Plating, Cadillac,  Ml                                RD
Verona Well Field, Battle Creek, MI                                RD
Verona Well Field, Battle Creek, MI                                RA
Eau Claire Municipal Well Field, Eau Claire, WI                    IRM
Schmaltz Dump, Harrison, WI                                       RD
Arcanum Iron & Metal, Oarke County,  OH                             RD
New Lyme Landfill, New Lyrae, OH                                    RD
Old Mill, Rock Creek, OH                                          RD
Old Mill, Rock Creek, OH                                          RA
Lehillier/Mankato Site, Lehillier/Mankato,  MN                      RD


EPA REGION VI

Site Name                                                       Stagea

Bayou Bonfuca, Slidell, LA                                        RD
Bayou Bonfuca, Slidell, LA                                        RA
Old Inger oil Refinery, Darrow,  LA                                RA
Bio-Ecology Systems, Inc., Grand Prairie, TX                       RA


REGION VII

Site Nane                                                       Stage3

Ellisville Site, Ellisville, MO                                    RA
Aidex Corp., Council Bluffs, IA                                   RA
                                      -106-

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8/14/85

                            SUPERFIKD COOTINGENCY PLAN
                                    SITE LIST


REGION VIII

Site Name                                                        Stage9

Wbodbury Chemical Co., Conuerce City, CO                           RA


EPA REGION IX .   .

Site Name                                                        Stage3

Celtor Chemical Works, Hocpa, CA                                   RD
Celtor Chanical Works, Hocpa, CA                                   RA
Del Nbrte County Pesticide, Crescent City, CA                      RD
San Gabriel Valley, La Puente, CA                                  IRM


REGION X

Site Name

Connencanent Bay, Well 12A, Tacona, WA
Western Processing Co., Inc., Kent, WA
Western Processing Co., Inc., Kent, WA
United Chrone Products, Inc., Corvallis, OR
a Stage refers to the phase of remedial action.  RD * detailed design stage or
development of plans and specifications; RA • ranedial action or the actual
implementation of the selected cleanup option; IRM « initial Remedial Measure
or implementation of a anall cleanup action prior to final remedy.


                                             U.S. Environmental Protection  Agency
                                      -107-  Region V, Library
                                             230 South Dearborn Street
                                                 -^0. i;iin'j;3  60604

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                 REGIONAL  PCJBLIC  AFFAIRS OFFICES
 REGION  I        EPA9115
 BROOKE  CHAMBERLAIN  COOK
 DIRECTOR
 OFFICE  OF  PUBLIC AFFAIRS
 JFK  FEDERAL  BUILDING
 BOSTON, MA  02203
 COMM:  (617)223-7223
 FTS:  223-6304

 REGION  II       EPA9213
 JIM  MARSHALL, DIRECTOR
 OFFICE  OF  PUBLIC AFFAIRS
 26 FEDERAL PLAZA
 NEW  YORK,  NEW YORK  10278
 COMM: (212)264-2515
 FTS:  264-2515

 REGION  III     EPA9315
 JANET LUFFY, ACTING DIRECTOR
 OFFICE OF  PUBLIC AFFAIRS
 841 CHESTNUT STREET
 PHILADELPHIA, PA  19107
 COMM: (215)597-9370
 FTS:  597-9370

 REGION  IV       EPA9413
 FRANK REDMOND,  DIRECTOR
 OFFICE OF  EXTERNAL  AFFAIRS
 345 COURTLAND STREET, N.E.
 ATLANTA, GA  30308
 COMM: (404)881-3004
 FTS:  257-3004

 REGION V        EPA9513
JON T. GRAND, DIRECTOR
 OFFICE OF  PUBLIC AFFAIRS
 230 S. DEARBORN STREET
 CHICAGO, IL  60604
 COMM: (312)353-2072
 FTS:  353-2072

CINCINNATI LAB  EPA8061
ANDREA TANNER
OFFICE OF  PUBLIC AFFAIRS
 ENVIRONMENTAL RESEARCH CENTER
 26 W. CLAIR
CINCINNATI, OH  45268
COMM: (513)684-7771
FTS:   684-7771
REGION VI      EPA9621
PHILIP CHARLES, DIRECTOR
OFFICE OF PUBLIC AFFAIRS
1201 ELM STREET
DALLAS, TX  75270
COMM: (214)767-2630
FTS:  729-2630

REGION VII     EPA9715
ROWENA MICHAELS, DIRECTOR
OFFICE OF PUBLIC AFFAIRS
726 MINNESOTA AVENUE
KANSAS CITY, KS 66101
COMM: (913)236-2803
FTS:  757-2803

REGION VIII    EPA9812
DORIS SANDERS, DIRECTOR
OFFICE OF EXTERNAL AFFAIRS
SUITE 900, 1860 LINCOLN ST.
DENVER, CO  80295
COMM: (303)837-5927
FTS:  327-5927

REGION IX      EPA9912
DEANNA WIEMAN, DIRECTOR
OFFICE OF EXTERNAL AFFAIRS
215 FREMONT STREET
SAN FRANCISCO, CA  94105
COMM: (415)974-8083
FTS:  454-8083

REGION X       EPA9018
BOB JACOBSON, DIRECTOR
OFFICE OF PUBLIC AFFAIRS
1200 SIXTH AVENUE
SEATTLE, WA  98101
COMM: (206)442-1203
FTS:  399-1203

RTP LAB        EPA8070
DEBBIE JANES
OFFICE OF PUBLIC AFFAIRS
ENVIRON. RESEARCH CENTER
RESEARCH TRIANGLE PARK, NC
COMM: (919)541-4577
FTS:  629-4577
                                -108-

-------
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