United States	Office of Solid Waste and OSWER 9355.0-79FS
Environmental Protection Emergency Response	EPA/540/F/01/009
Agency	June 2001
Superfund Post Construction
Completion: An Overview
The purpose of this fact sheet is to provide an overview of Superfund Post Construction Completion
(PCC), an integral part of the Superfund remedial program. The fact sheet lays out the goal and
objectives for Superfund PCC work, describes why this work is important, identifies the activities
included under the banner of PCC, and describes the roles and responsibilities of involved parties. The
fact sheet addresses these topics at an overview level of detail. Key references and a bibliography are
provided for more detailed information. The fact sheet addresses response actions completed under
the Superfund program, including response actions completed by Federal facilities under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The activities
described in this fact sheet do not address response actions taken under the EPA Brownfields program.
A. OVERVIEW
What is Super fund Post Construction
Completion?
Superfund PCC is the name given for several
activities generally undertaken at sites following
the construction of response actions. These
activities include operation and maintenance
and long-term response actions (or LTRAs);
institutional controls; five-year reviews;
optimization of remedies; and deletion from the
NPL. The goal of Superfund PCC is to ensure
that response
The policies and procedures set forth here are
intended as guidance to Agency and other
government employees. They do not constitute rule-
making by the Agency, and may not be relied on to
create a substantive or procedural right enforceable
by any other person. The Government may take
action that is at variance with the policies and
procedures in this document.	
actions provide for the long-term protection of
human health and the environment. The PCC
activities described in this fact sheet contribute
toward achieving this goal.
Why is this work important?
As of January 2001, more than 50% of the
sites on the Superfund National Priorities List
(NPL) were designated construction complete.
An additional 400 sites have completed initial
stages of remediation, and many of these should
achieve construction completion over the next
five years. Many of these sites have, or will
have, remedies that only allow for restricted
future uses due to contamination remaining on-
site, with combinations of engineering and
institutional controls to limit unacceptable
exposures. Also, many of these sites with
ground water contamination will require
ongoing remediation over many years to
achieve protective cleanup levels. Superfund
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PCC activities will help ensure that these
response actions perform as intended and
remain protective of human health and the
environment. Finally, EPA, States, potentially
responsible parties (PRPs), and other Federal
agencies have invested millions of dollars in site
characterization, and in the design and
implementation of response actions. Superfund
PCC activities will help preserve these financial
investments.
Who is involved in conducting PCC
activities?
Roles and responsibilities for the long-term care
of sites following a cleanup are specifically
addressed in CERCLA and the National Oil
and Hazardous Substances Pollution
Contingency Plan (NCP). EPA, States, PRPs,
and other Federal agencies all play an integral
role in Superfund PCC and should fulfill their
respective responsibilities to ensure that
response actions remain protective. The
primary responsibility for the long-term care of
response actions is vested in States for Fund-
financed sites, in viable and responsible PRPs
where they assume the lead for cleanup, and in
other Federal agencies for Federal facility sites.
Specific responsibilities for States, PRPs and
Federal agencies include operation and
maintenance of waste containment structures;
operation and maintenance of ground water
restoration or containment systems;
environmental monitoring; and implementation,
oversight and enforcement of institutional
controls required to ensure protectiveness.
Federal agencies assume additional
responsibilities when transferring property to
external parties during or after remediation.
EPA's role in PCC also is extensive. It may
include operating Fund-financed surface and
ground water restoration systems for up to ten
years (LTRAs); ensuring that operation and
maintenance and environmental monitoring is
performed; ensuring that institutional controls
are implemented and remain effective;
evaluating remedy performance and conducting
five-year reviews (or reviewing reports and
evaluating the protectiveness of response
actions when five-year reviews are performed
by States or other Federal agencies); and
deleting sites from the NPL once all response
actions are completed. EPA also has
responsibility for evaluating Federal agency
demonstrations that a remedial action is
"operating properly and successfully" as a
precondition to the transfer of Federally-owned
property.
Local government officials and citizens living
and working near Superfund PCC sites also
can play an important role. Site managers
should notify, and when appropriate involve,
local citizens and officials when conducting five-
year reviews, when considering changes to
response actions, and when deleting sites from
the NPL once the remediation process is
complete. Local citizens and officials frequently
can provide useful information related to the
performance of O&M, compliance with
physical and institutional controls, and
redevelopment activities that might be planned
or under consideration. These perspectives are
valuable when assessing if the remedy is
performing as intended, and whether the
remedy remains protective.
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How do external stakeholders view PCC
activities?
External stakeholder interest in PCC issues has
been extensive. (Please see the bibliography
for a partial listing of recent external
stakeholder research reports.) Several external
groups have coined the term "stewardship"
when referring to the long-term care of sites
following remediation. This term has evolved
around large and complex Federal facility sites
(e.g., DOE installations) but can apply to non-
Federal Superfund sites as well. Definitions for
stewardship suggested by these groups vary,
but generally include the following concepts:
site monitoring and maintenance;
implementation, monitoring and enforcement of
land use controls; environmental monitoring;
oversight and enforcement; information
collection and dissemination; and periodic
evaluation of remediation systems (including the
availability of new technology). These groups
suggest clear roles and responsibilities and
reliable funding as essential components of
stewardship.
Other parties, including the EPA Office of
Inspector General, the Environmental Law
Institute, and Resources For The Future, have
reviewed the Agency's performance of PCC
activities. This level of interest and review will
likely continue as the PCC workload grows.
B. POST CONSTRUCTION
COMPLETION ACTIVITIES
As noted, Superfund PCC encompasses a
number of related activities including: operation
and maintenance of engineered containment
remedies as well as ground water and surface
water restoration systems (including LTRAs);
implementation and management of institutional
controls; five-year reviews; optimization of
remedies based on actual operating experience;
and deletion from the NPL. These PCC
activities support four broad objectives:
Maintain the integrity of Superfund
response actions;
•	Provide relevant information to
stakeholders;
Ensure the efficiency of post
construction operations; and
•	Delete sites from the NPL
The following is an overview of the PCC
activities presented in this fact sheet, with
references and a bibliography for more detailed
information.
Operation and Maintenance and Long-term
Response Action
Operation and Maintenance. Operation and
Maintenance (O&M) are important
components of a Superfund response to ensure
that the remedy performs as intended. The
NCP, Subpart A, section 300.5, defines O&M
as the " .. measures required to maintain the
effectiveness of response actions." O&M
typically begins after the remedy is determined
to be "operational and functional" (see NCP
Subpart E, section 435(f)), and may be
required indefinitely for remedies that contain
waste on-site or include institutional controls.
O&M activities include maintaining engineered
containment structures; operating leachate and
gas collection systems; operating ground water
containment and restoration systems (following
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the LTRA period for Fund-financed sites with
restoration remedies); monitoring to ensure that
the remedy is performing as expected and the
environment is protected; and maintaining and
enforcing institutional controls and access
restrictions. See Highlight 1 for an example.
Under CERCLA and the NCP, performance of
O&M generally is the responsibility of the
States, PRPs or Federal facilities. EPA is
responsible for ensuring that the O&M work is
adequately performed. Specific EPA actions
may include ensuring that O&M and monitoring
reports are submitted through routine oversight,
or enforcement when necessary; reviewing
reports and evaluating monitoring results;
performing on-site inspections and documenting
the results. When appropriate, EPA may also
troubleshoot problems, and develop or evaluate
proposals for additional response actions or
adjustments to existing remedies, to achieve
objectives, improve performance, or reduce
costs.
Specific actions and roles and responsibilities
are defined in O&M Manuals and O&M Plans.
These documents provide technical and
administrative details regarding the performance
of O&M and should be prepared during
remedial design/remedial action for sites
requiring O&M. (See the EPA fact sheet
"Operation and Maintenance in the
Superfund Program " for a more detailed
summary of the O&M Manual and O&M
Plan.)
Highlight 1: Typical O&M Activities for
Landfill Caps
Maintenance of Landfill Cap
~	Mowing
~	Reseeding
~	Ensuring appropriate controls
for run off
~	Repairing cracks, animal
burrow damage, and areas of
settlement and erosion
Operation and Maintenance of Active
Components
~	Leachate collection and
treatment system
~	Gas collection and treatment
system
Monitor Land Use Controls
~	Monitor and enforce
institutional controls
~	Maintenance of access controls
(e.g., security fences)
• Environmental Monitoring
~	Monitoring to ensure that waste
in the containment area is not
migrating to ground water or
affecting the environment
Cap maintenance and land use restrictions
generally are required as long as waste remains
in place. Active leachate and gas collection
and treatment systems could be terminated if
measurements indicate the collected gas and
leachate can be released directly to the
environment.
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Long-term Response Action. A variation to
EPA's normal oversight role during O&M is
LTRA. The NCP, Subpart E, section
300.435, addresses financing of ground water
and surface water restoration systems as Fund-
financed remedial actions for up to ten years
after the remedy becomes operational and
functional. (LTRA generally does not apply for
sites where the remedial action objective is
limited to containment of ground water or
surface water contamination.) EPA may
assume a direct role in operating the restoration
system during the LTRA period, or system
operations can be assigned to the State (or to a
unit of local government or a political
subdivision) with funding provided from the
Trust Fund.
When cleanup goals are not achieved upon
completion of the ten year LTRA period, the
system is transferred to the State for continued
O&M, including follow-on monitoring that may
be required after cleanup goals have been
achieved. EPA should meet with the State one
to two years prior to the transfer date to finalize
a transfer plan and schedule. EPA and the
State should conduct a joint inspection of the
system and develop a list of actions that should
be completed prior to the transfer. An
optimization review (see discussion below)
should be considered to ensure that the system
is operating effectively and efficiently. Planning
for the LTRA transfer can be tied to a five-year
review where schedules coincide. A fact sheet
summarizing best practice for LTRA transfers is
under development.
Ground water remedies generally require active
management, and site managers should remain
involved in overseeing the performance of these
projects during LTRA and O&M.
Performance and monitoring data should be
maintained to support analysis and decision-
making. Specific areas of interest may include
ensuring that the public is being protected (e.g.,
the plume capture zone is being maintained);
ensuring that restoration of the aquifer is
progressing as planned; determining whether
there are significant changes to the assumptions
that were relied upon when selecting the
remedy; and determining when the active
portions of the remedy can be terminated. The
Superfund guidance "Presumptive Response
Strategy and Ex-situ Treatment
Technologies for Contaminated Ground
Water at CERCLA Sites " describes a phased
approach for ground water restoration which
acknowledges the complexities and
uncertainties involved with this work. The
guidance also describes a number of
refinements to enhance system performance
that can be considered, depending on site
conditions, during LTRA/O&M (see Highlight
2).
A useful tool that may help guide ground water
restoration projects, and in limited cases other
remedies involving O&M, is an "exit strategy."
Simply stated, an exit strategy should define the
decision criteria (response objectives from the
decision document), measurement strategies
(sampling locations and frequencies),
contingency plans (actions to consider when
remediation is not progressing as expected),
and roles and responsibilities for determining
when a response action is complete
(information collection, analysis, and decision-
making). Preparation of an exit strategy should
be considered for ground water and surface
water restoration projects, and for long-term
monitoring. The concept also may be useful for
in-situ soil remediation involving soil vapor
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extraction or bioremediation, and containment
remedies that include an active operational
component (e.g., leachate and/or gas collection
and treatment). Exit strategies should provide
for sufficient flexibility to address changing site
conditions, and should be reviewed and
adjusted, as needed, on a periodic basis.
Highlight 2: Examples of Remedy
Refinements for Ground Water
Pump/Treat Remedies
Change the extraction rate in some or
all wells
Cease extraction from some wells
Initiate "pulsed pumping"
Add or remove extraction or reinjection
wells or drains
Add or remove monitoring wells
Refine source control components of
the remedy
Refine enhanced recovery or in-situ
degradation components of remedy
Refine ex-situ treatment components
O&MZLTRA Summary
Purpose - Actions taken following the
construction of a response action to
achieve the objectives of the remedy
(e.g., achieve cleanup levels in the
aquifer; prevent waste migration and
exposure; maintain the integrity of the
remedy)
When Implemented - O&M and
LTRA begin once a remedy is
determined to be "operational and
functional" (generally up to one year
following the completion of
construction); O&M can extend
indefinitely; LTRA is limited to Fund-
financed surface water and ground
water restoration remedies and extends
up to 10 years
Who - States, PRPs and other Federal
agencies have responsibility for
performing O&M; EPA has the
responsibility to ensure that O&M is
performed properly; EPA has
operational responsibility for Fund-
financed surface water and ground
water restoration systems during LTRA
Kev References for O&M/LTRA:
National Oil and Hazardous Substances
Pollution Contingency Plan, 40 CFR Part 300,
Subpart E, section 435(f).
"Operation and Maintenance in the Superfund
Program," OSWER 9200.1-37FS, EPA 540-
F01-004, May 2001.
http://www, epa. gov/ superfund/pub s.htm
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"Presumptive Response Strategy and Ex-situ
Treatment Technologies for Contaminated
Ground Water at CERCLA Sites," OSWER
9283.1-12, EPA 540-R-96-023, October
1996.
http://www, epa. gov/ superfund/pub s.htm
Institutiona/ Contro/s
Institutional controls (also called land use
controls, and activity and use restrictions) are
non-engineered, administrative or legal
instruments that minimize the potential for
exposure to contamination by limiting land or
resource use. Institutional controls can play an
important role in remedy selection, and
generally are used in conjunction with, rather
than in lieu of, engineering measures for
treatment or containment. Institutional controls
can be used during all stages of a cleanup to
accomplish various objectives. They are
intended to minimize potential exposure when
contamination remaining on-site restricts the
unimpeded use of a site or a ground water
aquifer. Institutional controls also can be used
to ensure that engineered remedies are not
adversely affected by activities at the site.
Examples of institutional controls include
"proprietary controls" (e.g., easements and
restrictive covenants), "governmental controls"
(e.g., zoning restrictions, special permit
requirements), "informational devices" (e.g.,
State registries of contaminated property, deed
notices, advisories), and "enforcement controls"
(e.g., orders and consent decrees issued under
CERCLA). Estimates suggest more than 600
Superfund NPL sites, as of January 2001,
include one or more institutional controls as
part of the remedy to help ensure
protectiveness. Generally, institutional controls
selected as part of a remedy should be
implemented along with other components of
the remedy before Superfund sites can be
deleted from the NPL.
The fact sheet "Institutiona/ Contro/s: A Site
Managers Guide to Identifying, Evaluating
and Se/ecting Institutiona/ Contro/s at
Superfund and RCRA Corrective Action
C/eanups " provides useful guidance when
considering institutional controls as part of
response actions. This guidance is intended to
address concerns with institutional controls
frequently raised by external parties. These
include unclear legal authorities; unclear roles
and responsibilities to implement, monitor, and
enforce the controls; and uncertainty regarding
the potential to modify or remove controls over
time. When selecting institutional controls, the
site manager should evaluate the situation at the
site, define the needs that the institutional
controls are intended to address, identify the
kinds of legal and other tools available to meet
those needs, and coordinate with the
appropriate stakeholders (e.g., State and local
government officials).
Implementation of institutional controls
frequently lags behind the completion of
physical construction. In the PCC time frame,
site managers should ensure that appropriate
measures are taken by States, PRPs and other
Federal agencies to implement and maintain the
institutional controls. Once institutional controls
are in place, site managers should evaluate the
administrative and legal documentation, as well
as the physical site evidence, to ensure that they
are fully effective. This review should be an
integral part of the technical assessment
performed during operation and maintenance
inspections, as well as during the five-year
review process. EPA is developing additional
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guidance and piloting a tracking system to aid in
the implementation and long-term management
of institutional controls.
Institutional Controls Summary
Purpose - To prevent exposure to
contamination left on a site following
cleanup; to prevent exposure to
contamination until cleanup standards
are met (e.g., ground water
restoration); to protect components of
the remedy
When - Implemented during or
immediately following remedy
implementation consistent with the
requirements of the decision document;
maintained as long as needed to
minimize/control/mitigate exposure or
protect the remedy
Who - Determined on a site-specific
basis; site managers should work
closely with States, PRPs, other
Federal agencies, and local
governments as appropriate and seek
advance written agreements on who
will implement, maintain, and enforce
institutional controls
Key References for Institutional Controls:
National Oil and Hazardous Substances
Pollution Contingency Plan, 40 CFR Part 300,
Subpart E, sections 430 and 510.
"Institutional Controls: A Site Managers Guide
to Identifying, Evaluating and Selecting
Institutional Controls at Superfund and RCRA
Corrective Action Cleanups," OSWER
9355.0-74FS-P, EPA 540-F-00-005,
September 2000.
http://www, epa. gov/ superfund/pub s. htm
"Institutional Controls: A Site Managers Guide
to Implementing, Monitoring and Enforcing
Institutional Controls at Superfund and RCRA
Corrective Action Cleanups" (Guidance under
development, should be available during 2002
at http://www.epa.gov/superfund/pubs.htrn)
Five-year Reviews
Five-year reviews generally are required
following implementation of remedial actions
selected under section 121 of CERCLA, when
hazardous substances, pollutants, or
contaminants remain on-site above levels that
allow for unlimited use and unrestricted
exposure. In addition, five-year reviews
generally are appropriate for sites where
completion of the remedial action ultimately will
allow for unlimited use and unrestricted
exposure, but the remedy will take longer than
five years to reach cleanup levels. The purpose
of a five-year review is to evaluate the
implementation and performance of a remedy in
order to determine if the remedy remains
protective of human health and the
environment. Five-year reviews provide an
opportunity to identify potential problems or
issues with the remedial action, and adjust
O&M where necessary. Five-year reviews are
required at more than 800 NPL sites as of
January 2001.
EPA expects to release the "Comprehensive
Five-year Review Guidance " during FY
2001. This document describes the
requirements, roles and responsibilities, and
procedures for conducting five-year reviews.
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EPA typically has the responsibility for
conducting five-year reviews for Fund-financed
and enforcement-lead NPL sites, while other
Federal agencies have responsibility for
conducting reviews at Federal facility sites.
Through cooperative agreements, EPA can
provide funding to a State or Tribe to conduct
five-year reviews. Also, EPA can authorize
PRPs to conduct studies or investigations in
support of a five-year review even though
PRPs do not conduct actual reviews. In all
cases, EPA retains the responsibility for making
the protectiveness determination that is part of
the review.
Determining remedy protectiveness for a five-
year review involves examining three questions:
Is the remedy functioning as intended
by the decision document?
Are the exposure assumptions, toxicity
data, cleanup levels, and remedial
action objectives used at the time of the
remedy still valid?
Has any other information come to light
that could call into question the
protectiveness of the remedy?
Answers to these questions can be determined
through visual observation during site visits;
interviews with site stakeholders, and local
citizens and officials; review/evaluation of
response decision documents and existing
O&M and monitoring information; and, when
necessary, collection of new data. Findings of
the review are documented in a report which
should include an identification of issues;
recommendations and follow-up actions; and a
determination of whether the remedy is, or is
expected to be, protective of human health and
the environment. The report should identify the
party responsible for implementing
recommendations and follow-up actions, when
needed, as well as a timetable for completion.
Once completed, the five-year review report
should be made available to the public.
Completion of the five-year review should be
straightforward when site managers are actively
involved in managing LTRAs, overseeing
O&M and environmental monitoring, and
ensuring institutional controls are implemented
and effective.
Priorities for EPA include completing five-year
reviews on time, eliminating a backlog of
overdue reviews by the end of FY 2002, and
improving the quality of reviews and the
resulting reports through implementation of the
comprehensive guidance, and through training
provided to site managers. The program
completed more than 665 reviews through
September 2000, and more than 180 reviews
were completed during FY 2000. Between
140 and 180 reviews per year are scheduled
over the next several years.
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Five-year Review Summary
Purpose - To evaluate the
implementation and performance of a
remedy to determine whether the
remedy remains protective of human
health and the environment
When Implemented - Generally five
years following the initiation of a
CERCLA section 121 response action
resulting in contamination remaining on-
site after a cleanup that restricts future
uses, and every succeeding five years
so long as future uses remain restricted;
generally five years after the date of
construction completion for sites where
completion of the CERCLA Section
121 response action ultimately will
allow for unlimited use and unrestricted
exposure but the remedy will take
longer than five years to reach cleanup
levels
Who - EPA or States/Tribes when
acting as lead agency under the NCP;
Federal agencies for Federal facility
NPL sites; EPA retains responsibility
for protectiveness determination
Kev References for Five-vear Review:
National Oil and Hazardous Substances
Pollution Contingency Plan, 40 CFR Part 300,
Subpart E, section 430(f)
"Comprehensive Five-year Review Guidance",
OSWER Directive 9355.7-03B-P, EPA
540R-98-050. Pending, should be available
during FY 2001 at
http ://www. epa. gov/ superfund/pub s.htm
Optimization of Remediation Systems
Once remediation systems have been
functioning for a period of time, opportunities
may exist to optimize the operations of the
system. The purpose of optimization is to
identify potential changes that will improve the
effectiveness of the system and/or reduce
operating costs, without compromising the
protectiveness of the remedy or other response
objectives, through a comprehensive evaluation
of system performance. Optimization
recognizes that long-term remedial approaches
should not remain static, that conditions change
over time, and that better technologies, tools
and strategies evolve which allow for
continuous improvement of remedy
performance.
Optimization can be applied to ground water
restoration systems, as well as other
remediation technologies (e.g., soil vapor
extraction) and approaches (e.g., long-term
monitoring). Optimization generally follows
three steps: reviewing candidates and selecting
sites; conducting the evaluation using an
optimization protocol; evaluating results and
implementing the best recommendations.
Implementation may require an initial capital
investment in order to realize long-term
improvements and/or cost savings.
Optimization techniques can be applied to
ongoing response actions by EPA, States,
PRPs, and other Federal agencies. The entity
conducting the review should coordinate the
recommended changes to the remediation
system with appropriate
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parties (e.g., States) and obtain EPA approval,
where appropriate, prior to implementation.
EPA will complete up to 20 pilot optimization
studies of Fund-financed ground water
restoration systems during FY 2001. The
purpose of this initiative is to optimize the
performance of the selected remedies, and
increase awareness among EPA site managers
so that optimization becomes integrated into the
cleanup process.
These pilots will use the "Remedial Systems
Evaluation" (RSE) approach developed by the
U.S. Army Corps of Engineers. An RSE
involves an independent team of experts
working collaboratively with the site manager
and the operating contractor to evaluate the
performance of all major components of the
operating system (e.g., above ground treatment
system, extraction well network, monitoring
network and sampling protocols, and data
management). An RSE generally includes a
review of site data, a site visit, and report
preparation. It provides a comprehensive but
low-cost evaluation of the remediation system
and is an excellent first step in a continuous
improvement process. Recommendations can
highlight the need for additional information,
propose revisions to the extraction system (e.g.,
well locations and/or depths, pumping rates),
and/or modifications to the treatment process.
Optimization Summary
Purpose - To improve the performance
and/or reduce the operating costs of
remediation systems without
compromising protectiveness
When Implemented - Once actual
performance and cost data are
available
Who - Optimization studies can be
initiated by EPA at Fund-financed sites,
or by States, PRPs, or other Federal
agencies for sites under their lead;
recommendations should be reviewed
and approved by EPA, in coordination
with the State, prior to implementation
Key References for Optimization:
OERR Memorandum "Superfund Reform
Strategy, Implementation Memorandum:
Optimization of Fund-lead Ground Water
Pump and Treat (P&T) Systems", OSWER
Directive 9283.1-13, October 31, 2000.
http://www.epa.gov/superfund/pubs.htm
Optimization Web site:
http ://www.frtr. gov/optimization
EPA site managers are encouraged to review
other Fund-financed ground water restoration
projects not addressed by the pilot, and
consider proposals for optimization by external
parties, where the potential exists to improve
performance and/or reduce operating costs.
Additional information on optimization and the
RSE methodology is available at the web site
noted below.
Deletion from the NPL
EPA can delete sites from the NPL once all
response actions are complete and all cleanup
levels achieved. Procedures for deleting sites
are contained in the NCP, Subpart E, section
300.425, and "Closeout Procedures for
National Priorities List Sites. " In making a
determination to delete a site from the NPL,
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EPA must consider whether any of the
following criteria have been met:
Responsible or other parties have
implemented all appropriate response
actions required;
All appropriate Fund-financed
response under CERCLA has been
implemented, and no further response
action by responsible parties is
appropriate; or
The remedial investigation has shown
that the release poses no threat to
public health or the environment, and,
therefore, taking of remedial measures
is not appropriate.
EPA should consult with the State when
making this determination.
Under Agency policy as described in
"Closeout Procedures for National
Priorities List Sites'' site deletion has been
separated from the five-year review process.
This means that EPA can delete a site from the
NPL even when five-year reviews are required.
Deletion from the NPL does not preclude
eligibility for subsequent response actions. If
future site conditions warrant, response actions
can be taken by the PRPs, or using the Trust
Fund. If there is a significant release from a site
deleted from
the NPL, the site may be restored to the NPL
without calculating a new hazard-ranking score.
EPA also has the ability to delete portions of
NPL sites. The Agency may use partial
deletions to designate uncontaminated areas of
a site, or when portions of a site are cleaned up
and potentially available for productive use.
Requirements for partial deletion are essentially
the same as those noted above for a full
deletion. Procedurally, partial deletions require
clear documentation that supports the decision
and mapping of the portion to be deleted.
These are defined in "Closeout Procedures
for National Priorities List Sites''
EPA has released guidance to streamline and
accelerate the deletion process. The "Direct
Final Process for Deletions " guidance is
appropriate for sites where deletion or partial
deletion from the NPL is not expected to be
controversial, and the Agency does not expect
adverse comments from the public. The direct-
final process has been used successfully at
several sites, and the guidance includes
approved templates to aid in developing the
required notices.
As of January 1, 2001, EPA had deleted 230
sites from the NPL, and completed 21 partial
deletions. Expeditious deletion of sites is a
program emphasis. During FY 2001 and
beyond, EPA's goal is to delete 30 sites per
year.
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Deletion Summary
Purpose - To provide notice and take
comments on EPA's decision to
remove sites from the NPL
When - No further CERCLA response
is appropriate
Who - EPA has the responsibility for
deletions with State concurrence
Kev References for Deletion:
National Oil and Hazardous Substances
Pollution Contingency Plan, 40 CFR Part 300,
Section 425(e)
"Closeout Procedures for National Priorities
List Sites", OSWER Directive 9320.2-09A-P,
EPA 540-R-98-016, January 2000.
http://www, epa. gov/ superfund/pub s.htm
"Direct Final Process for Deletions", OSWER
Directive 9320.2-12-FS-P, October 31, 2000.
http://www, epa. gov/superfund/pub s.htm
C. ADDITIONAL INFORMATION
Copies of this document are available at the
Superfund web site,
http://www, epa. gov/superfund/pub s.htm.
Copies of this document may also be obtained
from the OERR Document Center (703) 603-
9232. General Questions regarding this topic
should be referred to the Call Center at 1-800-
424-9346. The subject matter specialist for
this document is Paul Nadeau of OERR.
D. BIBLIOGRAPHY
"Remedial Design/Remedial Action
Handbook", OSWER Directive 9355.0-04B,
EPA 540/R-95/059, PB95-963307, June
1995, (OERR Document Center).
"Guidance for Evaluating the Technical
Impracticability of Ground Water Restoration",
OSWER 9234.2-25, EPA/540-R-93-080,
PB93-963507, September 1993.
http ://www. epa. gov/ superfund/resources/ gwdo
cs/monit.htm
"Use of Monitored Natural Attenuation at
Superfund, RCRA Corrective Action, and
Underground Storage Tank Sites", OSWER
Directive 9200.4-17P, April 21, 1999.
http ://www. epa. gov/ superfund/resources/ gwdo
cs/tec_imp.htm
"A Guide to Developing and Documenting Cost
Estimates During the Feasibility Study", EPA
540-R-00-002, OSWER 9355.0-75, July
2000. http://www, epa. gov/ superfund/pub s.htm
"Institutional Controls and Transfer of Real
Property Under CERCLA Section 120
(h)(3)(A), (B) or (C)", February 2000.
http: //www, epa. gov/ swer/ffrr/guide.htm
"Guidance for Evaluation of Federal Agency
Determinations that Remedial Actions are
Operating Properly and Successfully Under
CERCLA Section 120(h)(3)", (Interim),
August 1996.
Chttp: //www, epa. gov/swer/ffrr/guide, htrn).
Memorandum, "Joint DOE/EPA Interim Policy
Statement on Leasing Under the Hall
Amendment", June 23 and June 30, 1998.
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http://www.epa. gov/ swer/ffrr/ guide.htm
"Institutional Controls: A Reference Manual",
Work Group Draft, US EPA, March 1998.
"Backlog of Five-year Review Reports
Increased Nearly Threefold", US EPA Office
of Inspector General Audit Report, 1999-P-
218, September 30, 1999.
http://www.epa.gov/oigearth/eroom.htm
DOD Memorandum "Responsibility for
Additional Environmental Cleanup after
Transfer of Real Property", July 25, 1997.
http://www.dtic.mil/environdod/publish.htm
DUSD(ES/CL) Memorandum "Policy on Land
Use Controls Associated with Environmental
Restoration Activities", Jan 17, 2001.
http://www.dtic.mil/environdod/publish.htm
DUSD(ES/CL) Memorandum "Guidance on
Land Use Control Agreements with Regulatory
Agencies, Mar 2, 2001.
http://www.dtic.mil/environdod/publish.htm
"The Environmental Site Closeout Process
Guide", September 1999 (available from
www.afbca.hq.af.mil/closeout/
DOE Memorandum "Long-term Stewardship
Responsibility" January 19, 2001.
http: //Its. apps. em. doe. gov/ center
"A Report To Congress on Long-Term
Stewardship" Volume 1 and 2, DOE/EM-
0563, January 2001.
http: //Its. apps. em. doe, gov/center
DOE Guidance "Long-ter Stewardship
Implementation Plan Guidance", Draft January ,
2001.
http: //Its. apps. em. doe, gov/center
"Standard Guide for the Use of Activity and
Use Limitations, Including Institutional and
Engineering Controls", ASTM Standard Guide,
Designation: E 2091-00. www.astm.org
"Rolling Stewardship: Beyond Institutional
Controls, Preparing Future Generations for
Long-Term Environmental Cleanups", National
Environmental Policy Institute, December
1999. www.nepi.org
"Protecting Public Health at Superfund Sites,
Can Institutional Controls Meet the Challenge",
Environmental Law Institute, ELI Doc
#dl0.01, 2000. www.eli.org
"Long-Term Institutional Management of US
Department of Energy Legacy Waste Sites",
National Research Council, August 2000.
www.national-academies.org
"Long-Term Stewardship and the Nuclear
Weapons Complex: The Challenge Ahead",
Resources for the Future, June 1998.
www.rff.org
"Linking Land Use and Superfund Cleanups:
Unchartered Territory", Resources for the
Future, June 1997. www.rff.org
"Long-Term Stewardship of Contaminated
Sites, Trust Funds as Mechanisms for
Financing and Oversight", Resources for the
Future, December 2000. www.rff.org
"Beyond Fences, Brownfields and the
Challenges of Land Use Controls", No. 42495,
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International City/County Management
Association, www.icma.org
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