EPA 910/9-91-045
                United States
                Environmental Protection
                Agency	
Region 10
1200 Sixth Avenue
Seattle WA 98101
                Hazardous Waste Division
Supertund Branch
ftEFA       Superfund:

                Progress in Region 10
Alaska
Idaho
Oregon
Washington
September 1991

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                                  Super Fund: Progress  In Region  10
Executive Summary

The purpose of this report is to provide perspective on the
successes and challenges of the Environmental Protection
Agency (EPA) Region 10 Superfund program. Superfund,
the Federal program to clean up hazardous waste sites, is
the focus of substantial activity in Region 10. Fifty of the
oven 100 sites investigated by Region 10 are listed among
the most hazardous in the nation.

Superfund is now an established program. Its ambitious
task and unique liability scheme  gave the program an
extended adolescence. Now Superfund shows rtselftobe
a strong program to protect people and the environment.

EPA has worked closely with States, communities, and
other interested parties to develop effective Superfund
cleanup remedies. Citizens, environmental groups, State
and  local officials, and industry  representatives have
participated in cleanup decisions. EPA Region 10 has used
a variety of approaches, including newsletters, public
meetings, and community workgroups, to inform and involve
the public in its Superfund activities. Public involvement
has contributed significantly to the successes of Region
10's program.

Region 10Targeted Approach. The Region 10 Superfund
program has aggressively moved to protect human health
and the environment:

•  Sites are investigated quickly and early actions are
   taken to protect people and the environment.
•  The worst sitesareaddressedfirst, and evencomplicated
   sites are being cleaned up. Complex sites are stabilized
   quicklyto protect human health until a complete cleanup
   is undertaken.
•  The majority of cleanup work is financed by parties
   responsible for pollution at Superfund sites.


Thefirststepinthe Superfund program is to makesites safe
for people and theenvironment. At 63 sites inthe Northwest,
EPAhas immediately removed hazardous wasteortaken
other actions to stabilize and secure sites. In many cases,
EPA'semergencycleanupsorother immediate actions do
more than provide safety - they succeed in completely
cleaning up the site.
•  Initial Investigations and Quick Cleanups Are a
   Priority. Region 10hasinvestigated'oven, 100'sites
   reported to it and performed emergency cleanups at
   63 sites, many of which resulted in clean sites. Over
   700 of the sites reported, those not posing the most
   serious threats, have been  referred to States for
   further action if necessary.

Superfund'snext step is to cleanup sites, tackling the worst
sites first. Site characterization is an important activity. By
determining the source  and pathways for exposure to
people and the environment, EPA can identify the worst
sites and at least stabilize them until cleanup can occur.
EPA has foundthat by breaking large sites into afew smaller
units, it can attack first the most contaminated areaon-site
or prevent the contamination from moving. The smaller
units are more rapidly characterized, which means that
cleanup can start sooner.

•  Focus on Smaller Bites for Clean Sites. Consistent
   with the national strategy for Superfund, Region 10
   initiates early cleanups to reduce exposure to people
   and the environment. In Region 10, 23 emergency
   actions and 28 cleanup activities (6 initiated early to
   address significant threats) are underway or completed
   at the National Priorities List (NPL) sites managed by
   EPA.

EPA uses strong enforcement to ensure that those
responsible for the pollution clean it up at their own cost.

•  Superfund Leverages  Cleanup by Responsible
   Parties. In Region 10, more than 50 percent of the
   emergency cleanups and 90 percent of the interim
   and final cleanups are being performed by responsible
   parties.   Their contribution toward emergency
   cleanups,  site studies, and cleanups is worth over
   $300 million, four times what has been spent in
   Federal Superfund dollars.

Hazardous waste problems created in the past 40 or 50
years cannot be cleaned up overnight. The folbwing pages
provide a brief overview of  cleanup progress to date in
Region 10. The structure of the report follows the Superfund
cleanup process:

•  First Steps: Investigating Threats, Quick Cleanups
•  Long-Term Cleanups:  NPL Sites
•  Enforcement: Polluters Clean Up or Pay Up
•  Conclusion: Superfund: Successful, Not Perfect
   AllinformationinthisreportappliestoEPA'sNorthwestRegion(Regipn 10): Alaska, Washington, Idaho,andOregon. The
   jnformationcoversRegion10SuperfurdsiteslistBdontheNationalPrioritiesList(NPU,exceptNPLsitesmanagedbyStates
   and by Federal facilities, e.g., those operated by the Departments of Defense and Energy.

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        el
Super Fund: Progress in  Region  10
                 First Steps:  Investigating Threats, Quick Cleanups
Finding the Worst Problems

   Over 1,100 of the 1,176 potential Superfund sites
identified in the Northwest have been investigated by EPA
Region 10. These sites were reported as possible threats
by local governments, police or fire departments, nearby
businesses, neighboring residents, or State or EPA
inspectors. EPA's site investigations are comprehensive -
- they combine on-site sampling and inspections with
detailed investigations of business records of past activities.

   Fifty of these sites pose serious long-term threats, and
EPA listed them on the National  Priorities List (NPL).
Another63 sites have been cleaned upor stabilized by EPA
                 with short-term immediate work (called emergency cleanups
                 or "removals"). Over 700 of the reported sites do not meet
                 the criteria for listing on the Superfund National Priorities
                 List (NPL) and are referred to State and local agencies for
                 their appropriate follow-up, if needed.

                    Sites in the screening process will continueto be added
                 to the National Priority List. New listing criteria will increase
                 the number of sites listed  because of environmental
                 concerns.
      Protecting A Community's Water Supply

    In 1981, EPA discovered that two major wells of the
 Lakewood Water District, which serves more than 10,000
 people south of Tacoma, Washington, were contaminated
 with chlorinated organic chemicals. The Lakewood Water
 District took the wells out of production and notified its
 customers of the problem.  Customers were requested to
 follow a water conservation plan.

    From 1981 to 1983, EPA investigated the site to determine
 the source of the contamination.  EPA found that the
 contamination was coming from a commercial dry-cleaner.
 TheStateissuedanenforcementorderrequiringthecleaner
 to cease dumping solvent-containing matenals  into the
 septic system.

    EPAnextstudiedtTBatmentsystems which would provide
 water to the water district and restrict the  spread of
 contaminants in the aquifer. Lakewood Water District was
 concerned that the two shut wells were critical for providing
 drinking water and fire protection to 600 residents. EPA
 decided to construct aeration towers at the two  wells to
 remove the organic solvents. The treated water was then
 distributed through the existing public water supply.  The
 towers wereconstructed and in operation within six months.

    Following a more detailed investigation of the soil and
 groundwatercontaminationatthesitein 1985, EPAdecided
 to add a treatment system  to extract solvents from
 contaminated soil. The groundwater and soils treatment
 systems are expected to complete the site cleanup next
 year.
                 Figure 1:
                 Region 10 Site Reporting and Investigation
                 Many sites are reported. Not all require cleanup, but steps must
                 be taken to determine how each reported site must be dealt
                 with.
                                                   (Sites Cleaned Up
                                                     or Stabllbed)

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                                  Super Fund:  Progress in  Region 10
Protecting People and the Environment from Urgent
Threats.

   EPA addresses the most urgent threats immediately.
EPA's emergency crews remove hazardous materials and
stabilize and secure sites. If drinking water is contaminated,
EPA provides bottled water immediately and connects
homes to a safe water supply as soon as possible.

   While emergency cleanups are fast responses, they
also can be significant efforts. Barrels with mysterious
contents must be sampled, and safely removed in case of
dangerous reactions or explosions.  Proper disposal or
recycling must also be assured before removal from the
site. EPA directly and through enforcement actions has
performed emergency cleanups at 86sites (23 atNPL sites,
63 at non-NPL sites) in the Northwest.

   Many times, an emergency cleanup is all that  is
necessary to clean up a site. Whether for accidental spills
ordeliberatedumping, EPAcanoften remove contamination
completely, especially if it is concentrated. While EPA
moves quickly to remove the hazardous materials, EPA
takes time to ensure the action is thorough. Emergency
cleanups then result in a clean, safe site.

   A typical emergency cleanup costs between $250
thousand and $2 million and takes from several weeks to a
year to complete.  In most cases, the site is then clean
enough for use.
                                     Cleaning Up an Illegal Dump

    In January 1990, EPA's Office ofCriminal Investigators notified Region 10'sSuperfundprogram aboutpossible illegal
 disposal of hazardous wasteat Ditch Creek Ranch in Wimer, Oregon. This information was forwarded from the State of Oregon
 DepartmentofEnvironmentalQuality. Superfund's site assessment discovered hazardous sludge and soils. Because of high
 levels of lead and copper, the site was determined to present an imminent threat to human health and the environment

    The emergency cleanup began with a community meeting that led to an investigation of the whole ranch. Duetoprevious
 gold mininginthearea, itwas difficulttodistinguish between mining disturbances anddisturbances causedby illegaldisposal
 of hazardous waste. Site activities included testing of 16 domestic wells to ascertain the threat posed to neighbors, 117 soil
 samples, 42 surface water samples, electromagnetic surveys, ground penetrating radar, xray florescence, aerial photo
 interpretation, and surface geology. Most of these activities were conducted between April and August, 1990.

    In September, EPA authorized emergency cleanup actions to address the contaminated areas. The owner of the ranch,
 who also owned Rogue Valley Circuits, a printed circuit board manufacturing and electroplating company, agreed to perform
 further studies on the extent ol'contamination, to remove the waste, and clean up the site under EPA Order and supervision.

    Emergency cleanup activities began in November 1990. Soil was excavated, debris sorted out, and all contaminated
 material removed. The dump area was covered with hay and planted with seeds and conifer saplings for slope stabilization.
 Wastewatergenerated'during cleaning and decontamination was transported to a licensed facility. Since the ranch includes
 the recharge area for the local drinking water aquifer, groundwater monitoring was installed for regular sampling. The
 neighboringwellshaveyettoshowcontamination.Atotalof35truckloadsofsoiT,and5truckloadsofdebris,wereremoved,
 treated, and disposed at a hazardous waste landfill. The last truck left the site in January,  1991.

    On May 28,1991, the PRP was found guilty of illegal transport and disposal of hazardous waste and penalized almost $1
 million. This included$960,000forthe cleanup anda criminal'fine o1'$20,000.

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                                 Super Fund:  Progress in  Region  10
                            Long-Term Cleanups:  NPL Sites
   Fifty sites listed on the NPL are in EPA Region 10
(excluding Federal facilities). Consistent with EPA'shistory
ofastrong Federal-State partnership, States have assumed
management of 14 of these sites, the majority in the State
of Washington. The long-term cleanup of these NPL sites
includes: (1) a comprehensive study of the contamination
and the technologies to clean it up; (2) the .design of the
chosen technology, and (3) the construction and operation
ofthetreatmentsystem. Contaminated soil andgroundwater
may take many years of treatment until a site meets cleanup
standards.

   In Region 10, manysites are well onthewaytocleanup.
Region 10 and responsible parties have completed or are
conducting 66 site investigations and 28 separate cleanup
actions at the 36 sites managed by EPA.

   In all, 31 of the 36 NPL sites managed by EPA are
actively being worked on. Of the four sites where action is
pending, three were just listed on the NPL in August, 1991.
One of the 36 sites is completely clean, verified by final
sampling, and the site is no longer on the NPL.
                   Mega-Sites

    Region 10 has been aggressive in listing very large sites
 on the NPL in special circumstances. These "mega-sites"
 allow EPA to more effectively address a variety of public
 health and environmental problems not covered by other
 State or Federal laws.  However, these sites also present
 management and communication challenges, since site
 investigationorcleanupmayoccursimultaneousryatdifferent
 units of the site.  The Superfund program is generally
 designed to deal with relatively small discrete problems,
 such as abandoned and leaking drums of toxic waste. In
 Region 10, we have listed several of these "mega-sites" on
 the NPL:

 •   Commencement Bay (Tacoma, Washington)
 •   South Tacoma Channel (Tacoma,
    Washington)

 •   Eagle Harbor (Bainbridge Island, Washington)

 •   Harbor Island (Seattle, Washington)
 •   Bunker Hill (Silver Valley, Idaho)
Figure 2:
Region 10 NPL Site Cleanups
                   NPL
               Region
                3$ sites
             (EPA
* Shows activities underway or completed.  In Region 10,
 several large or complex NPL sites are managed as more
 than one cleanup site.

 Significant action has taken place at 32 of 36
       NPL sites under EPA jurisdiction.
            (including one NPL deletion)
           Smaller Bites for Clean Sites

    Region 10 is breaking mega-sites and other Superfund
 sites into smaller, more manageable pieces. It often makes
 sense to identify parts of the larger site where early cleanups
 can be done to greatly reduce public or environmental
 exposure.  Contamination in these areas is easier to
 characterize and the cleanup remedy is easierto design and
 implement This means actual cleanup can start sooner and
 progress more efficiently. This also means that Region 10
 can work on the worst sites first, consistent with the national
 strategy for Superfund.

    Anotherresultisthatthenumberof sites Region Wdeals
 with is significantly largerthan the 36 EPA-managed sites on
 the NPL For example, the Tacoma Tarpits site is an
 independent cleanup unit within the larger Commencement
 Bay site.  The Tarpits is a 30 acre site containing coal
 gasification wasfes, lead, and PCBs. Each cleanup unit
 presents unique technical and legal challenges.

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                                   Super Fund:  Progress in Region 10
                                                       \
Early Cleanups Make Sites Safe in the Interim

   Not all NPL cleanups need to wait for completion of the
comprehensive site study. EPAtackles the worst problems
at each site first, often beginning some early cleanup action
while site  studies are still underway.  EPA Region 10
reviews NPL sites to determine whether an emergency
cleanupor interim action is necessary to make the site safe
until final cleanup can occur. Interim cleanup actions tend
to be larger-scale activities to stabilize the site. Many times
emergency or interim cleanup actions are performed by the
responsible parties. To date, 23 emergency response
actions havebeeninitiatedorcompletedtocontrolimmediate
threats at NPL sites. In addition, of the 28 cleanup actions
described above, 6 were interim cleanup actions performed
by EPA Region 10 or responsible parties. These early
cleanups ensure that NPL sites pose no immediatethreats
to public health orthe environment, and they speed up the
long term cleanup of the sites.
                                      Early Cleanup at an NPL Site

     The Commencement Bay South Tacoma Channel site covers 2.5 square miles in Tacoma, Washington. The site includes
 thteemajorcleanupareas, one of which is adrinking water wellfield. Well12Aistheprincipalwellofthe 13 wells used by Tacoma
 to meet peak summer and emergency water demands. Aproduction well, it can produce 5 million gallons per day. The well
 wasremovedfromservicein 1981 when the City of Tacoma found chlorinated solvents contaminating the well. EPA proposed
 the site for listing in 1981 and listed itin 1983.

     Studiesofthewellfield area in 1982 showed that Well 12A was contaminated by previous nearby activities, including waste
 oil and solvent reclamations processes. Because of Tacoma's reliance on Well 12A, the City requested that action occur as
 sopnasppssible. In January 1983, EPA evaluated treatment options. In March, EPA selected a large five tower air stripping
 unit Design and construction followed immediately. Operation began in July 1983. Well 12A, whose treated water now met
 drinkingwaterstandards, was returned to service. While the site itself needed further cleanup, Tacoma could once again rely
 onWell12A.

     Cleanup activities continued. Site studies of other areas demonstrated the extent of the contamination and the sources.
 This enabled EPA to pursue litigation against responsible parties, take action to prevent further contamination, and address
 cleanup of the entire site.

     Litigation against Burlington Northern Railroad, owner of one of the properties contaminating Well 12A, resulted in a 1985
 setttementwhereby Burlington Northemagreedtoexcavate and dispose of contaminated soil at acostbetween$500,000and
 costs.

    While pursuing litigation, EPA took actions to halt the spread of contamination and undertake long-term cleanup of the site.
 To prevent further migration of contaminants toward Well 12A, EPA constructed a carbon adsorption groundwater treatment
 system near the Time Oil property. The system began operation in 1988 and its successful continuous operation has kept
 the plume in check. Over200 million gallons of groundwater have been treated and over 7,500 pounds of organic chemicals
 removed to date. ContaminantlevelsbetweenthesystemandWell12Ahavebeenreducedbytwoordersofmagnitudeand
 levels in Well 12A by one-fifth.

    EPA will install the final cleanup measure, a soil aeration system, this fall. A network of 23 vacuum extraction wells will
 be hooked up to blowers. Air will pass through contaminated soil, evaporatingthe solvents. The contaminated air will be
 captured in the vacuum wells and treated aboveground to recover the solvents. Final site cleanup is expected to be complete
 in 1997.

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                                Super Fund: Progress in  Region  10
Cleanups Involve Large Quantities of Toxic Waste

   Cleanups frequently entail  removing  hazardous
materials from the site, emptying lagoons of hazardous
liquids, dealing with large volumes of contaminated soil,
proper disposal of these materials, building watertreatment
units andtemporary storage facilities, or bring ing in mobile
incineration units. Even at small sites, these activities can
be major construction projects.

   Large quantities of contaminated material must be
addressed at Super-fund sites. Once hazardous material
contaminates soil, surface water, or groundwater, the soil
or water frequently becomes hazardous material as well.
Over time, the contamination may spread across large
areas, all  of which  is  addressed in the cleanup.   One
indicatorof Region 10's cleanup progess is the enormous
volume of hazardous material treated or removed from
Superfund sites.
Figure 3:
Region 10 Cleanups Address Contamination
Estimated Amount of Hazardous Materials Treated or Removed
from Sites (through September 1990)
     3.7 Million Gallons
       Liquid Waste
   52 Million Lbs.
Contaminated Debris
                             Groundwater
                                                      226,000 Cu. Yd.
                                                           Soil
                       5.2 Million Gallons per Day
                         Treated Groundwater

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                                 Super Fund: Progress in Region 10
                     Enforcement: Polluters Clean Up or Pay Up
   The very name "Superfund" conjures up a picture of
publicly fundedcteanupsfinanced by thespecial Superfund
taxes. But EPA has been remarkably effective at using
enforcement to  produce far more cleanup work by
responsible partiesthan would be possible using just public
funds. In Region 10, for every dollar that has been spent
from public funds, responsible parties have spent four
dollars on cleanup work under EPA enforcement orders or
judicial decrees.  Region 10 Superfund enforcement has
resulted in $305 million of cleanup and investigation.
Flgun 4:
Region 10 Superfund Dollars Leverage Cleanup by
Responsible Parties*	-
                             mment Cleanup Costs
 Estimated Value of Work Performed by Responsible
 Parties Through EPA Enforcement
  Includes removals, site studies, cleanups, and miscellaneous costs
  reimbursed or paid in advance to EPA
   Region 10 has been successful in obtaining responsible
party cleanups. Region 10 uses its Superfund resources to
focuson emergency cleanups, wherethe need for speed is
greatest, and on site studies, often establishing the basis for
later negotiations with responsible parties. Asshowninthe
graph following, responsible parties have then supplied
morethan90 percent ofthe resources forNPLsitecleanups,
the most expensive step in the process.
Flgun 5:
Responsible Parties Pay for Cleanups in Region 10
    200
                                                             Removals  Site Studies   Cleanups
   When EPA cannot pursuade responsible parties to
perform removals or  long-term cleanups,  EPA uses
Superfundtoensurethatprogresstowardcleanupatthesite
continues. EPA closely documents its expenditures at the
site, including overhead. EPA then sues responsibleparties
to recoverthese costs. Region 10 has been very successful
in its efforts to recover its costs. In addition to the cleanup
cost shown  in Rgure 5, responsible parties have also
reimbursed  the  Federal government  $20 million for
emergency cleanups, site studies, cleanups, and EPA
oversight to date. In addition, responsible parties have
paid $12 million in advance toward EPA cleanups.

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                                Super Fund: Progress in Region 10
                                        Conclusion
                         Superfund: Successful,  Not Perfect
   Region 10's Superfund program has significant
successes to its credit:

•  Preliminary investigation of 94 percent of the over 1,100
   sites reported to Region 10 to date.

•  Responsible parties paying for 90 percent of interim
   and final Superfund site cleanups in Region 10.

•  Cleanup efforts targeted to  addressing the most
   significant threats to people and the environment, with
   29 early cleanup actions (23 emergency cleanups and
   6 interim cleanup actions) u nderway or completed at the
   36 NPL sites managed by EPA.
   Despite.this progress, Region 10 still faces a number
of challenges: large and complex sites; complextechnical
and legal issues; reducing contractoroverhead costs; and
continuing an aggressive prog ram to address the worst site
problems first and to ensure that responsible parties pay
their fair share of cleanup costs.

   Region 10 is committed to maintain its successful
efforts, and to aggressively address problems as they are
identified. We will continue to work with States, affected
communities, responsible parties, and others as appropriate
to devefoptimely and effective Superfund cleanups. Looking
ahead, Region 10willcontinueto look fornew ways to speed
upthe Superfund investigation and clean up process, improve
contracts management, and continue a strong enforcement
program, including dealing fairly and effectively with smaller
responsible parties.

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                                Setting the Record  Straight
 TheSuperfundprogram has received much scrutiny. Some concerns are validandEPA isworkingto improve the program
 Otr^rs may be based on incomplete inforntation or reflect a lack of understanding of iMmplex legal andtechnicalissues. '

 "Super-fund Spends Lots of Money, But Nothing Ever Gets Cleaned Up"

 •  Just counting deletions from the National Priorities List does not tell the whole story.

 •  Thereare28cleanupscompletedorinprogressherein Region 10 alone.

 •  AlthoughthereisonlyonedeletionfromtheNationalPrioritiesListinRegion 10 and only 36 nationally, deletions do not
   measureprogressinsitecleanup. Many NPL sites involve contaminated groundwater which can take yearsto correct
   even when au other work at the site is completed. EPA established very stringent criteria fordeletions, including careful
   study and public comment

 •  EPA continues to push forward to clean up the most hazardous parts of Superfund sites first

 "Superfund Is Not Making the Polluter Pay for Cleanup."

 •  In Region  10, for every dollar that has been spent from public funds, responsible parties have spent four dollars on
   investigation or cleanup work through EPA enforcement

 •  Responsible parties have contributed 90 percent of the costs of NPL site cleanups in Region 10.

 Too Much of Superfund Goes to Pay Contractors"

 •  Region lObpayinghigherthananticpatedcontractoroverheadcosts, duetoanenforcementprogramthathasbeen very
   successful, resulting in significant cleanup by responsible parties.

 •  Several years ago, EPA signed contracts with cleanup firms for work financed by Superfund taxes. These contracts
   guaranteed a minimumamountofworktothecontractors, basedon EPA's experience that Superfund would have to be
   used to clean up most sites.

 •  Since the  contracts were signed,  EPA enforcement has encouraged responsible parties to step forward at an
   unprecedented rate, resulting in less contractor work.

 •  EPA must still pay contract overhead costs, because of the terms of the contracts. EPA is actively working to cut these
   costs • one price of enforcement success.

 "Can Groundwater Really Be Cleaned Up?"

 •  The Superfund program spends a considerable amount of time and money in cleaning up and protecting groundwater
   sources for future generations. Thousands of pounds of contaminants have been removed from important aquifers.

 •  Improving the effectiveness of techniques to clean up aquifers is the subject of intense EPA research.
 •  Thestandardmethodtocleanpollutedgroundwateristoinstalla well to pump and treat the water, releasing ittp drinking
   water systems, rivers, or back to the aquifer.  This process does effectively clean the treated water. However, it is not as
   effective at cleaning up the aquifer itself. Some of the contaminants tend to stick to the rock or soil of the aquifer. Cleaning
   theaquiferissomewhatlikecleaningsoapoutofasponge;itrequiresalotofrinsing. Rightnow,hcaneasitytake20years
   to "rinse'an aquifer, and some will never be totally clean. EPA will continue to search for improvements to this technology.

 "Superfund Is Overkill. The Time and Money Just Aren't Worth It,"

•  Somepeoplefeelthis way, especiallythosethatareaskedtopayforcleanupsbecauseoftheirpastinvolvementatasite.
•  CongressplacedstringentcleanupcriteriaonSuperfundsiteswhenthelawwasreauthorizedin 1986. These cleanup
   standards are intended to ensure that Superfund sites are as clean as possible, and that public health is protected. EPA
   typically is required to clean sites to a point where the threat of disease, especially cancer, is virtually eliminated.

•  People who live near Superfund sites generally feel that cleanup is worth the costto protect their health.

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