UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
FEB3 1994
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: Response to Congressmen Dingell
FROM: Henry L. Longest II, Director
Office of Emergency and Remedi
TO:
Bruce M. Diamond, Director
Office of Waste Programs
Swift
use
cement
Director, Waste Management Division
Regions I, IV, V, VII
Director, Emergency and Remedial Response Division
Region II
Director, Hazardous Waste Management Division
Regions III, VI, VIII, IX
Director, Hazardous Waste Division
Region X
Director, Environmental Services Division
Regions I, VI, VII, X
PURPOSE
To distribute OSWER's response to the 21 questions submitted
by Congressmen Dingell and Swift.
BACKGROUND
Last summer we undertook a challenging project to gather
detailed site specific data on all 1249 sites on the National
Priorities List. This effort required substantial work by many
of your staff; especially the Regional Project Managers (RPMs).
Our headquarters staff visited each Region and interviewed over
450 RPMs on issues relating to NPL sites. The RPMs provided us
with information such as current and future site land use;
standard industrial classification (SIC) codes for site
activites; media addressed in RODS; groundwater data; number of
PRPS; capital costs; and site durations. Your regional
management teams, including the Regional Information Management
-------
-2-
Coordinators, were very supportive in assisting our headquarters
teams in obtaining over 700 site documents that were reviewed in
headquarters. Without the enthusiastic support of the Regions,
this effort would not have been as successful as we believe it
has been.
IMPLEMENTATION
We invite your review of the information provided in the
attached national summary information provided to Congressmen
Dingell and Swift. We anticipate that as the reauthorization
debate continues, there will be additional queries from Congress,
our outside constituents, advisory groups, as well as our own EPA
staff.
We would again like to thank you and your staffs for your
support in this most important endeavor. Please let us know if
you have any questions or comments. For specific information on
the project, we ask that your staff contact Michael Cullen (703)
603-8730 or Suzanne Wells (703) 603-8710.
Attachment
cc: Elliott P. Laws
Jerry Clifford
Timothy Fields, Jr.
Superfund Branch Chiefs, Regions I-X
Information Management Coordinators, Regions I-X
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JAM
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
Honorable John D. Dingell OSWER DIRECTIVE 9200.2-21
chairman
Committee on Energy and Commerce
U.S. House of Representatives
Washington, D.C. 20515-6115
Dear Mr. Chairman:
I am pleased to forward to you the responses to the 21
questions on the Superfund program you submitted in your
July 19, 1993, letter to Administrator Browner.
As you know, over the past several months we visited our ten
EPA Regions and obtained information on the 1,249 current and
deleted sites on the National Priorities List. We discussed site
specific issues with over 450 Regional Remedial Project Managers
as well as other staff. We believe the information we have
gathered will assist Congress in its evaluation and oversight of
the Superfund program.
During the process of gathering and analyzing data, we had
periodic meetings with your staff and the suggested outside
policy analysts to review our progress. We now look forward to
working with you and your staffs as you review the information.
listrator
Enclosures
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eonttw«MiM50%r*cycMdllb*r
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JAN 28 JS34
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
Honorable Al Swift
Chairman
Subcommittee on Transportation
and Hazardous Materials
U.S. House of Representatives
Washington, D.C. 20515-6115
Dear Mr. Chairman:
I am pleased to forward to yru the responses to the 21
questions on the Superfund program you submitted in your
July 19, 1993, letter to Administrator Browner.
As you know, over the past several months we visited our ten
EPA Regions and obtained information on the 1,249 current and
deleted sites on the National Priorities List. We discussed site
specific issues with over 450 Regional Remedial Project Managers
as well as other staff. We believe the information we have
gathered will assist Congress in its evaluation and oversight of
the Superfund program.
During the process of gathering and analyzing data, we had
periodic meetings with your staff and the suggested outside
policy analysts to review our progress. We now look forward to
working with you and your staffs as you review the information.
linistrator
Enclosures
rtocycM/ftocyctabto
Prtntod wHti Soy/Onoto Ink on piper that
-------
EXECUTIVE SUMMARY
INTRODUCTION
Over the past year, as the debate over the latest reauthorization of Superfund
got underway, EPA faced increasing requests for data about the Superfund program
from Congress, independent researchers and advocacy groups. These requests
coincided with a major Agency effort to make Superfund data more comprehensible,
comprehensive and accessible to a broader audience. Also, in July 1993,
Congressmen Swift and Dingell wrote to Administrator Browner requesting detailed
information on NPL sites in preparation for upcoming reauthorization hearings. To
address these requests, EPA interviewed Regional site managers and collected
information from site documents about every National Priorities List (NPL) site.
EPA compiled the results of months of data gathering and analysis in the form
of responses to the Congressmen's twenty-one specific questions. These data have
the advantage of reflecting the experiences of the Regional site managers on a site-by-
site basis rather than relying on anecdotal information. Considered as a whole, they
represent an important step forward in using real-world data to analyze vital areas of
the Superfund program and help set the stage for reauthorization.
THE QUESTIONS
Congressmen Swift and Dingell asked twenty-one questions on topics ranging
from capital costs to identifying the past and potential future uses of NPL sites. The
Congressmen's original letter appears as Attachment A to this report The questions
appear in this report in the order asked, and each response is labelled with the
corresponding question number. The responses begin with a summary statement,
followed by more detailed information as requested by the Congressmen. The data
sources for each answer are provided, along with any necessary background
information.
Some of the answers confirm what past analyses had shown, while others offer
new insights into the program. For example, the average cost to dean up a non-
Federal facility site is about $25 million. Many sites however, cost significantly less
than the average would indicate. Only a small percentage of sites fall into the high
cost category (more than $100 million). Large volumes of contaminated media was
the most common factor contributing to capital costs exceeding $20 million.
-------
Despite a common perception of sites having large numbers of potentially
responsible parties (PRPs), our data show that more than half of NPL sites have fewer
than ten responsible parties, and about one fifth have only a single PRP. On the other
hand, about one third of sites have at least one non-viable responsible party, and
about one half of sites have potential de minimis parties.
As expected, an overwhelming number of sites have groundwater and/or soil
contamination as the primary contamination problems, and drinking water supplies are
affected at most sites with groundwater problems.
The most common current on-site land uses are industrial, abandoned and
commercial, although 15% of sites currently have residents living on-site. The most
common current land use surrounding sites is residential. About 73 million people live
within 4 miles of an NPL site (based on 1990 Census data). The most common
expected future site uses were industrial, residential and commercial, while land use
adjacent to the site is expected to be residential. Future human consumption of
groundwater is assumed at more than half of the sites.
EPA expects about 75 to 95 sites to be added to the NPL in 1994. From 1995
through the end of 1999, between 340 and 370 sites will be added. By the end of the
year 2000, we expect to complete construction at between one half and two thirds of
current NPL sites.
CONCLUSION
EPA is committed to protecting public health and the environment through the
Superfund program. The Agency recognizes that there are areas of the program that
can and should be made more effective and efficient The data presented in this
report and the new information EPA has collected ensure there will be reliable data
that reflect actual field experience at Superfund sites to support the reauthorization
debate.
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07. 29. 93 02:11 PM * SWIFT TRANS SUB ADM P02 L
JULZ 11993
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» 1993
The Honorable Carol M. Browner
Administrator
Environmental Protection Agency
401 M Street, S.H.
Washington, D.C. 20460
Dear Administrator Browner:
As we undertake reauthori2ation of the Comprehensive Envi-
ronmental Response Compensation and Liability Act of 1980, as
amended, in the Committee on Energy and Commerce, we are inter-
ested in obtaining certain basic information to assist Congress
in its evaluation and oversight of the Superfund program.
This letter seeks certain specific data about each facility
on the Superfund National Priorities List. The data requested
has been identified with the assistance of a number of outside
policy analysts and we believe is essential to a better
understanding of this complex and regionally delegated program.
We request this information pursuant to Rules X and XI of
the Rules of the House of Representatives, and ask that it be
led to the Committee no later than September IS, 1993.
Since
nge
Committee on Energy
and Commerce
Subc
an
t
on Transportation
s Materials
cc: The Honorable Carlos J. Moorhead, Ranking Minority Member
Committee on Energy and Commerce
The Honorable Michael O. Oxley, Ranking Minority Member
Subcommittee on Transportation and Hazardous Materials
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°7- 29' 93 02: 11 PM *SWIFT TRANS SUB ADM PQ3
Attachment
to Letter of Chairman Dingell and Swift
July 19, 1993
provide the following data, on a facility-iy-facility basis r
tor each facility on the National Priorities List, separated into
tvo categories * 1) non-federal and 2) federal.
1. What is the current expected total capital cost for cleanup?
What ie the expected average annual eperatione and maintenance
(06N) coat for each facility, and the number of years that O&H will
be required? If the facility haa been added to the HPL so recently
that reliable coat estimates can not be made/ please so indicate,
and indicate the date of listing.
2. Please indicate if the facility is expected to cost over $20
million in capital costs. If so, what factor" are responsible
(please respond in terms of the factors listed on the attached,
"Checklist of Factors for Analysis of Expensive Facilities")?
3. HOW many RODs have been signed? What media (groundwater,
surface water, sediment, surface waste, or soil) have been
addressed by each ROD signed to date? How many additional RODs are
expected, and what media remain to be addressed in the future RODs?
4. When is construction completion expected?
5. For each facility for which an RI/FS was initiated after
October 17, 1986 and for which a risk assessment has been
performed, please indicate: the date of risk assessment
completion; media addressed (groundwater, surface water, sediment,
surface waste, or soil); and whether additional risk assessments
are anticipated for the facility. On the basis of these risk
assessments, please quantify:
a. the baseline risk posed by the facility;
b. the future risk projected to be posed by the facility
if unremediated;
c. the future risk projected by the facility when
remediated.
6* Where a remedy has been selected for contaminated soil, please
indicate the remedy that was selected and the principal
contaminants addressed.
7. For each facility at which a ROD addressed groundwater, please
provide the following:
a. current use of groundwater adjacent to the facility
(e.g^. drinking, irrigation, industrial) ;
b. current groundwater classification adjacent to the
facility fft.o. . sole source, potential source, etc.);
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07. 29. 93 02:11 PM *SWIFT TRANS SUB _ADM_ P04
e. assumption for future groundwater use;
d. whether risk assessment assumed future consumption
of plum* per BB or future dovngradient consumption
of groundwater; and
e. if the remedy relied upon natural attenuation
for cleanup of plume.
8. For each facility where a remedy ha» been selected for
groundwatar, please indicate the remedy that was selected and
whether DNAPL contamination is highly likely. For each groundwater
remedy where DNAPL contamination is highly likely, please provide
the following informations
a. Was the ROD(S) involving groundwater signed before or
after EPA's May 1993 guidance on DNAPL sites?
b. Did the selected remedy seek to return groundwater to
drinking water standards?
c. Did tho selected remedy have containment pumping as its
goal?
d. Did EPA invoke a technology feasibility waiver to avoid
applying ARARs to the DNAPL cleanup?
9. Please provide the complete set of cleanup standards
(contaminant by contaminant, for each media) used at the facility.
Indicate whether the standard was based on risk assessment*- MCL,
state standard, or other (indicate what other). Where a cleanup
standard has been established for soil based on a risk assessment
initiated after October 17, 1986, please indicate the date of
completion of the risk assessment and each of the exposure
assumptions used for each cleanup standard as follows:
a. whether the driving factor establishing the standard was
soil ingest ion, leaching to groundwater or other route of exposure,
(please indicate what other, e.g.. dermal, inhalation );
b. number of total years and number of days per year of
exposure to the facility, broken down by age of exposed individual
where appropriate;
c. amount of soil ingested, contacted, or inhaled per day of
exposure, broken down by age of exposed individual where
appropriate;
d. whether exposure to contaminated soil is assumed to occur
to maximum concentrations found at the facility, average
concentrations, or other (indicate what other);
e. whether any of the contaminants used to calculate risk
are assumed to degrade in soil over time (thereby, decreasing
exposure).
10. Please provide the following information:
a. current land use of facility per se;
b. current adjacent land use;
c. if current adjacent land use includes residential
use, number of people within 1/4 mile of the facility,
1 mile of the facility;
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07. 29. 93 02:11 PM * SWIFT TRANS SUB ADM P05
d. assumption for future land use of facility per ve
(industrial, residential, etc.); and
e. assumption for future adjacent land use (industrial,
residential, etc.).
11. Fleas* Identify whether ATSDR has indicated that a more in-
depth study under section 104(i) is needed after the health
assessment is completed, indicate for each such facility whether
such a study is planned, underway or completed, and identify the
type of study.
12. For non-federal sites only, please identify what kind of
operation/activity waa present at the facility, from the list of
possible operations/activities listed below, only one category
should apply ta aaeh facility.
A. industrial
Che&ical manufacturing
Wood preserving
Petroleum refinery
Tannery
Printing
Paper mill
Asbestos manufacturing
Foundries
Textile mill
Rubber and plastics
Primary metals
Fabricated metals products
Electronic and electrical equipment
Electric power production and distribution
Mining — please specify one of the following categories:
a) metals
b) coal
o) oil and gas
d) non-metallic mineral
Coal gasification plant
Oil and gas pipelines
Dry cleaners
Pesticides formulators
Other:
B. Waste Management
(Facilities would be placed in a "waste management11 category
pnly if the primary operations at the facility are/were waste
management activities, e.g.. a chemical plant that has an on-site
landfill should be categorized as a chemical plant; a public
landfill, commercial landfill that takes waste on a fee-for-sexvice
basis or an off-site private landfill would all fall under the
category of waste management.)
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Q7. 29. 93 02:11 PM * SWIFT TRANS SUB ADM ? u o
1. Recycling
a) drum reconditioning
b) used oil recycling
c) battery recycling
d) solvents recycling
e) other recycling: _
2. Landfills
(Should be used for sites where the only or
primary waste management activity is a landfill/
landfills. Facilities with a variety of waste
management activities are categorised more
broadly under "other waste management,")
a) municipal landfill: publicly owned, fee-for-
service (or for municipally generated trash only),
only municipal-type waste.
b) municipal co-disposal landfills publicly
owned, fee-for-service, both municipal-type and
industrial wastes.
c) Commercial landfill: privately owned, fee-for-
service, municipal or industrial waste, but not
both.
d) Commercial co-disposal landfill: privately
owned, fee-for-service, municipal-type and
industrial waste.
e) Captive industrial landfill: privately owned,
not fee-for-service, fi.e.. landfill is for the use
of one company/organization), only industrial waste.
f) Captive co-disposal landfill: as above, but
mixed industrial and office/municipal-type waste.
3. Other waste management
(These sites could include a landfill, but also have
other waste management operations, such as
incinerators, surface Impoundments, waste piles,
etc.)
a) Municipal waste management — has waste
management activities other than or in addition to
a landfill: publicly owned, municipal-type and
industrial wastes managed.
b) Commercial industrial waste management —
includes a variety of waste management activities/
operations, e.g.. incinerators: privately
owned, fee-for-servioe, industrial waste managed.
c) Captive industrial waste management: sai*e as
above, except that facilities are only for the use
of one company/organization (i.e.f not commercially
available on a fee-for-service basis).
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07. 29. 93 02:11 PM *SWIFT TRANS SUB ADM P07
C. "Miscellaneous1* facilities
(Some Superfund facilities do not have either industrial
or waste management operations on-site. The facilities are often
contaminated by off-site operations or activities or as a result of
spills.) Specific categories include:
Retail/office/industrial areass industrial area/park/
complex/development/property/operations
Hells/water areas: municipal/private/residential/comm«rclal
wells, groundwater contamination, tidal estuaries/waterways/
creeks/rivers, hydroelectric dans
Railroadss railroad yard/property, electric train repair
operations, railroad loading and storage areas
Airports: airports, airfields
Trucking operations: trucking operations, truck leasing
operations, vacuum truck terminals
Farms/other pesticide application areas: farms, farmers'
cooperatives, horse fitables, cropland, pig farms, dairy
farms, orchards
Universities: universities, research laboratories,
agricultural research centers, schools
Illegal disposal areas: illegal dumping/disposal areas
Storage areas: warehouses, storage facilities
Residential areas: apartment complexes, residential areas/
developments/property, city contamination
Repair operations: aircraft and electrical appliance repair
operations (NOT recycling operations)
Cleaning operations
D. Other
Multiple operations: sites with multiple operations
currently on-site
Other: (describe)
13. Please identify whether the best estimate of the total number
of PRPs associated with the facility that could potentially by held
liable under section 107 (irrespective of whether EPA decides to
pursue all of them) is: (1), (2-10), (11-50), (51-100), (101-300),
(301-1000), (1001+).
14. For each facility where there is only one potentially
responsible party, please indicate whether that PRP is an
owner/operator.
15. Please indicate where the only potentially responsible parties
are owner/opera tors (i.e. f no hazardous substances were contributed
to the facility by offsite generator/transporters).
16. Please indicate whether sufficient volumetric data exists to
establish whether there are PRPs who contributed snail amounts of
hazardous substances to the facility and could be considered sJe.
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07. 29. 93 02:11 PM * SWIFT TRANS SUB_^AJ)M P08
minimis parties. For each such facility/ indicate the number of
potential dj| minimi« parties. For each such facility, please
identify where a waste-in list has been or could be prepared based
on the data available to EPA.
17. Please indicate where there are orphan parties fi.a.. parties
who are not financially viable or can not be located) and where
sufficient volumetric data exists, pleaee provide the best estimate
of the percentage, by volume, of waste contributed to the site by
generator/transporter orphan parties. For each of those same
facilities, indicate whether all the owner/operators are orphan
parties.
18. Please indicate whether the government believes that there are
no financially viable parties, or no parties that can be found, and
that the Trust Fund will have to pick up 100% of site study and
cleanup costs?
19. Please indicate whether the facility is fund-lead or expected
to be fund-lead.
20. Please indicate where EPA has expended funds that are
recoverable under section 107, indicate the amount of , those
recoverable expenditures, indicate whether a cost recovery action
has been filed to recover those funds, whether funds have been
recovered and the amount that has been recovered, and indicate
whether or not the statute of limitations is expected to be a bar
to cost recovery of any amount.
21. Please obtain from regional officials in each region their
best informed judgment with respect to the number of facilities in
their region that will be added to the NPL in the period from
October 1, 1993 to October 1, 1994, and in the five year period
from October 1, 1994 to October 1, 1999. To the extent possible,
please obtain information concerning the types of facilities that
will be added to the NPL during the periods referenced above. In
addition, please obtain the opinion of regional officials with
respect to the number of facilities currently on CERCLIS, other
than those for which a determination. has been made not to list,
which are likely ultimately to be added to the NPL.
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07. 29. 93 02:11 PM *SWIFT TRANS SUB ADM P09
CHECKLIST OF FACTORS FOR ANALYSIS OF EXPENSIVE FACILITIES
(Mark primary factors with a "1"; cheek all other major factors.)
Facility characteristics:
large volume of contaminated soil/sediment
large volume of contaminated groundvater
facility hazards pose danger to cleanup worker*
other ,._
Remedy characteristic*:
high-unit-cost treatment of soil/sediment
high-unit-cost treatment of groundwater
high-unit-cost treatment of surface water
second remedy required after first failed
other
mi
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Question #1
Capital Costs for National Priorities List (NPL) Sites:
Site cleanup activities are typically divided into multiple projects, called operable units (OUs). On
average, there are 1.8 OUs per non-Federal Facility site. The average capital cost to conduct an OU
remedial action project is $12.1 million for a non-Federal Facilitysite. This translates to an average site
capital cost of $21.8 million for the typical non-Federal Facility site. Site assessment, studies and
design comprise approximately 11% of total site costs, resulting in an average cost estimate of
approximately $25 million for non-Federal Facility sites.
In addition, most sites have annual operation and maintenance (O&M) costs of $50,000 or more for
each OU extending for approximately 21 years.
NOTE: The cost estimates were collected from site manager surveys which reported costs in
ranges for each OU. The average OU capital costs were calculated by averaging the
midpoint of the estimated cost ranges.
What is the current expected total capital cost for cleanup?
The average cost to clean up non-Federal Facility sites
listed as final or deleted on the NPL is expected to be
approximately $25 million. This average is impacted by
the relatively small number of sites with very high
cleanup costs; 16% of the OUs account for over 60% of
all capital cleanup costs incurred at NPL sites. The
majority of projects (69%) have capital costs of less than
$10 million and 38% have capital costs of less than $3
million. Approximately 89% of the total site cleanup
cost is for capital costs; the remaining 11 % includes site
assessment, study and design activities.
The approach used to calculate the reported capital costs
was to average the midpoint of the remedial action OU
cost range estimates provided by site managers (i.e.,
$12.1 million for non-Federal Facility sites and $11.3
million for Federal Facilities) and take into account the
11% of total site costs commonly spent on site assess-
ment, study and design activities. This calculation
resulted in an average OU cost of $13.6 million for non-
Federal Facility sites and $12.7 million for Federal
Facilities. The average site cost ofclose to $25 million
for non-Federal Facility sites was extrapolated by mul-
tiplying the average OU cost by the average number of
OUs (1.8 at non-Federal Facility sites). The estimate for
non-Federal Facility site cleanup cost is in line with the
previously reported estimate of $25 million derived from
an analysis of non-Federal Facility RODs. (No corre-
sponding exhibit).
What is the expected average annual O&M cost tor each
facility?
For all OUs (Fund-lead, PRP-lead and Federal Facili-
ties), most O&M costs were more than $50,000 annu-
ally. (No corresponding exhibit).
What is the expected number of yean that O&M will be
required?
For State-lead O&M OUs, the estimated average num-
ber of years for O&M is 19. On average, O&M is
expected to last 21 years for PRP-lead OUs and 23 yean
for Federal Facility OUs. (No corresponding exhibit).
Question #1
Date: 1/2&9
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If the facility has been added to the NPL so recently that
reliable cost estimates cannot be made, please so
indicate and indicate the date of listing.
Reliable site cleanup cost estimates are not available for
316 sites. Of these 316 sites, 168 have PRP-lead clean-
ups for which cost data are proprietary and not readily
available to EPA. Seventy (70) cleanups are at Federal
Facilities for which the Federal agencies have not made
their cost information available to EPA. Twelve (12) are
sites where the State has taken responsibility for cleanup
activities and no Fund dollars are involved. Sixty-six
(66) are Fund-lead sites that are listed on the NPL, but
reliable estimates for total capital cleanup costs are not
available. These 66 sites were published as final NPL
sites in the Federal Register as follows:
1983 26 sites listed
1984 5 sites listed
1986 7 sites listed
1987 2 sites listed
1989 14 sites listed
1990 7 sites listed
1992 5 sites listed
(No corresponding exhibit).
Data Source
1) The source: 1) August 1993 RPM Data Collec-
tion (questions E13, E32, E48, ESI and ES2a),
2) CERCLIS and 3) EPA cost analysis of
RODs.
2) The full universe of sites addressed by the
question: The 1,249 final and deleted sites
listed on the NPL as of August 1993.
3) The subset of the universe for which data are
provided: The 1,161 final and deleted sites
listed on the NPL responding to the questions.
Background Information
What is an Operable Unit (OU)?
An OU is the division of a project into meaning-
ful work elements (events) that can be imple-
mented on different schedules, resulting in
acceleration of cleanups. OUs allow certain
elements of a project to be started ahead of
others to lessen the hazards present at the site
and to complete some work elements ahead of
more complex and hazardous work elements.
Thus, each element can move at its own rate to
completion. Examples of two separate OUs are
source control and groundwater cleanup.
What is a median?
A median has a two-part definition: 1) the
medan is defined as the middle observation of
an odd-numbered group of observations that are
ordered from smallest to largest; or 2) the
median is defined as the number halfway
between the two middle observations of an
even-numbered group of observations that are
ordered from smallest to largest
What is the definition of capital costs?
Capital costs include aU remedial action costs,
including construction, up to 10 years of operat-
ing a groundwater treatment system, any
operational and functional period prior to
acceptance of the project and can include any
service contracts for operating costs (e.g.,
burning materials in an incinerator). Operation
and maintenance and removal costs are not
covered in capital cost estimates.
Whatl*OperattonafKJlWntonaiK»(OWI)?
O&M encompasses those activities necessary
to ensure the continued effectivenewofthe
remedy after the remedtal action goals are met,
or after the 10 year operational period tnaj'EPA
can pay for groundwater treatment systems.
The cost of O&M is borne by the PRP ora State
government (except in a very limited number of
circumstances). Therefore, there is no Fund-
lead O&M.
Date: 1/26/94
Quastontl
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Question #2
Factors Contributing to High Cleanup Costs:
Site managers expect capital costs to exceed S20 million at 296 sites (232 non-Federal Facility sites
and 64 Federal Facilities). The most common factors contributing to these estimates are large volumes
of contaminated media, site complexities and high treatment costs.
Please indicate if the facility is expected to cost over
S20 million in capital costs. If so, what factors are
responsible?
Overall. 64 of the 123 Federal Facilities reporting (52%)
expect to have capital costs greater than S20 million.
while only 232 of the 1.126 non-Federal Facility sites
reporting (21%) expect to have capital costs greater than
S20 million.
The most common factor for sites with capital costs
expected to exceed $20 million is large volumes of
contaminated media (e.g., soil, groundwater). This
reason was cited in 205 (88%) of the 232 non-Federal
Facility sites and 48 (75%) of the 64 Federal Facilities
expecting capital costs greater than S20 million. Site
complexities and high technology costs also were cited
often as major factors driving high cost sites. {See
Exhibit 2-1).
NOTE: Similar cost factors were grouped to facilitate
data analysis. (See "Major Cost Factor Groups" in
Exhibit 2-1). The factors, that make up each group, are
individually described in the key above Exhibit 2-1.
More than one factor may be cited for any given site,
therefore, the number of sites providing individual cost
factors in the table in Exhibit 2-1 does not total to the cost
factor groups illustrated in the graphic.
Data Source
1) The source: August 1993 RPM Data Collection
(questions E49 and E50).
2) The full universe of sites addressed by the
question: The 1,249 final and deleted sites on the
NPLasofJuly 1993.
3) The subset of the universe for which data are
provided: Those 296 sites for which site managers
expected capital costs to exceed $20 million tot"
1.249 sites reporting).
Background Information
What is the definition of capital costs?
Capital costs encompass all remedial action
costs including construction, up to 10 years of
operating a groundwater treatment system, any
operational and functional period prior to
acceptance of the project and can include
service contracts for operating costs (e.g.,
burning materials in an incinerator). Operation
and maintenance, and removal costs are not
covered in capital cost estimates.
Question #2
Date: 1/26/94
-------
Exhibit 2-1
Major Factors Contributing to Capital Cleanup Costs Expected to Exceed $20 Million
Descriptions of bidhndufli radon g|
01 = Uig» volume ol highly contamnatad soifsludge/sdti waste
02 = Luge volume d sol oveial
us - Large voune or canmnraieo wuntent
04 = Uige votwne of cantmnited gmundwiter
05 = Site hazards POM dangers K> deanup woken
06 = Complex hydrageolagy
07 = Comptax fnodure of contVTinnis
08 » Hah unit cast of treatment or (oMkidgetoM waste
09 * Njh unit cost ct tmttnent 01 gRiundvaier
10 » Hgti iril cost d BBMnen of utee wtler
1 1 = Second «emedy wu requred alter im rameoy faied
12 = Ofter (sptdfied by ate managers)
' = Laige area to dean is) (ban tMier' responses)
• = ttgh disposal costs (htm Wher- responses)
• = Appfcafcjn of ARARs (horn Oner1 rgcproa)
99 = Unknown
%NO*>
1%
59.1%
375%
16.4%
46.6%
1U%
2E3%
25.0%
332%
20.7%
35%
ilfh
31.0%
5.6%
3.4%
3.4%
05%
fNan-
FsflMl
S*M
137
87
38
108
29
61
SB
77
48
9
5
72
13
8
8
2
££?!
(-M)
45.3%
48.4%
23.4%
574%
26.6%
355%
375%
215%
25J%
6J%
1.6%
64.1%
32.8%
3.1%
4.7%
3.1%
f**nt
=«CMM
29
31
15
37
17
23
24
14
16
4
1
41
21
2
3
2
H! Federal Facilities
D Non-Federal
Facility Sites
Large Site High Danger to Large Area to Application of High Disposal Second
Volumes of Complexities Treatment Workers (05) dean Up* ARARs' Costs' Necessary
ContaminatBd (0647) Costs Remedy
Mecta (08-10) (11)
(01-04)
Major Cost Factor Groups
More than one factor can be cited for any given site. Seventy-four (74) non-Federal Facility sites and 43 Federal
Facilities reported 'Other* and/or 'Unknown' factors. These responses cited by site managers include such factors as
difficulty of wetland remediation and presence of DNAPLs.
Date: V2&94
Question K
-------
Question #3
Media Evaluated in Records of Decision (RODs):
A wide variety of media are affected by Superfund site contamination. Contamination of the
groundwater and soil media are the most frequent problems identified at sites. Site managers report
two-thirds of the signed RODs addressed groundwater and one-half addressed soils. More than one-
half of the planned RODs are also expected to address contaminated groundwater and soil.
How many sites have signed RODs?
Site managers reported information on 789 National Prior-
ity List (NPL) sites with signed RODs. Site managers
reported on 1,135 RODs at these 789 sites. (At the end of
fiscal year 1993.885 sites had signed RODs). The number
of RODs signed is greater than the number of sites because
more than one ROD may be signed at a site, f No corre-
sponding exhibit).
How many media are addressed by each signed ROD?
A ROD may address more than one contaminated media.
A wide variety of media are affected by Superfund sites
(See Exhibit 3-1). The groundwater medium was ad-
dressed in two-thirds of the RODs. These RODs were
signed at 622 sites. The soil medium was addressed in one-
half of the RODs. These RODs were signed at 478 sites.
NOTE: Some sites may have RODs that address both ground-
water or soil.
Background Information
What is a Record of Decision (ROD)?
Upon completion of site studies, EPA selects
a remedy for site contamination. This remedy
is detailed in the ROD. The ROD can either
address the entire site cleanup (more than
one medium), one phase of the site cleanup
(for example, soil contamination), or determine
that no further action is needed.
How many additional RODs are expected, and what
media remains to be addressed in the future RODs?
Site managers reported that542sites will need a ROD in the
future. They expect 986 RODs at these 542 sites (See
Exhibit 3-2). The groundwater medium is expected to be
addressed in 625 RODs. These RODs are planned at 412
sites. The soil medium is expected to be addressed in 588
RODs. These RODs are planned at 348 sites.
The data provided here cannot answer the question of how
much work remains to be done at NPL sites. The data
provided do not consider the area! extent of problems at
sites, the risk yet to be remediated, the complexity of site
problems, nor do they exclude those media where no action
is needed.
Data Source
1) The source: August 1993 RPM Data Collection
(questions £32, E34 and E36).
2) The full universe of sites addressed by the ques-
tion: The 1.249 final and deleted sites listed on
the NPL as of July 1993 (1.126 non-Federal
Facility sites and 123 Federal Facilities).
3) The subset of the universe for which data are
provided: RPMs reported on 1,170 sites with
signed or planned RODs. The number of sites is
less than the total number of RODs because more
than one ROD may be signed or planned at a site.
Question #3
Date: 1/26/94
-------
Exhibit 3-1
Signed Superfund Records of Decision (RODs)
Address Contamination of Different Medte
690
GROUNDWATER
SOIL
SEDIMENT
SURFACE WATER
SLUDGE
513
234 |17 =251 Signed
160 111 =171 Signed
132 19 =141 Signed
122
SOUP WASTE
8 =130 Signed
DEBRIS
MAN-MADE
STRUCTURES
AIR
LIQUID WASTE
116 I 6 =122 Signed
89
3 =92 Signed
82 I 7 =89 Signed
80
H
= 745 Signed
R
= 562 Signed
4 =84 Signed
Non-Federal Facility RODs
Federal Facility RODs
NOTE Other media have been evaluated in 19 signed RODs. The signed numbers total more than too 1,135 signed RODs reported
because a ROD may analyze more than one contaminated medium. In ado^on, the number of RODs signed is greater than the number
of total sitBS with signed RODs because more than one ROD may be signed at a site.
Date: 7/2694
Question #3
-------
Exhibit 3-2
Planned Superfund Records of Decision (RODs)
Will Adtess Contamination of Different Media
79 • 79 • =158 Planned
= 97 Planned
= 67 Planned
= 625 Planned
= 588 Planned
I I Non-Federal Facility RODs
• Federal Facility RODs
NOTE' Other media Witt be evaluated inl28 planned RODs. Site managers answered Vntoown'for the type of media that wil be
evaluated in 77 planned RODs. The planned numbers total more than the 986 planned RODs reported because a ROD may analyze
more than one contaminated medium. In addhkn, the number of planned RCIOs is greater than the njmber of total ste
RODs, because more than one ROD may be planned at a site.
Question t3
Date: 1/26/94
-------
uestion #4
Construction Completions:
By the end of the year 2000. over one-half of the 1.249 sites listed as final and deleted on the National
Priorities List (NPL) are projected to have construction completed. This number could go as high as
two-thirds of all sites. Construction completions beyond the year 2000 are difficult to project and can
be assessed later when more site-specific information is available.
When is construction completion expected?
To determine when construction will be completed for
sites currently on the NPL. EPA looked to two sources of
information: 1) historical data and trends, and 2) site-
specific projections. The first approach is the more
conservative of the two because it accounts for real
world delays encountered during past cleanups.
EPA first looked at historical trends to determine future
rates of construction completion. In fiscal year 1992(FY
92), EPA completed construction at 86 sites, while in FY
93, EPA reported construction completion at 68 sites, for
a total of 217 sites by the end of FY 93. Because the
construction completion definition was established in
1992, the FY 92 accomplishments included "old" sites
that would have met the criteria in previous years. In
both FY 92 and FY 93. the construction completion
accomplishments were most likely less complex than are
expected in future years. Consequently. EPA estimates
construction completion at 63 sites per year through the
end of the century. This yearly rate combined with the
224 sites completed by December 31, 1993, brings the
projected total to 665 sites with construction completion
by the end of calendar year 2000. iSee Exhibit 4-1).
Construction completions also were assessed using re-
sponses from site managers to a site-specific question
that asked the year construction completion is expected.
The site-specific answers may not account for real world
delays that are difficult to predict. Examples of possible
delays are Supenund resource limitations, unforeseen
site conditions encountered after remedy selection and
enforcement issues. Using the site-specific approach.
the projection is 965 construction completions by the
end of calendar year 2000. (See Exhibit 4-1i.
How many of the sites for which construction is com-
plete were single party sites?
Of the 217 sites where construction was completed b>
September 30. 1993. 49 sites (23%) are single-paru
sites. I No corresponding exhibit).
What is the mean and median number of PRPs at sites
for which construction is complete?
Since the data were reported in ranges, the mean and
median cannot be calculated. The most frequentK
selected range - between 2 and 10 PRPs - was reported
at 46% of the sites. (No corresponding exhibit I.
Background Information
What is construction completion?
Construction completion at sites refers to the
point in the cleanup process at which physical
construction is complete for all remedial and
removal work required at the entire site. Con-
struction is officially complete when a document
has been signed by EPA stating that all neces-
sary remediation has been finished. While no
further construction is anticipated at the site,
there may still be a need for long-term, on-site
activity before specified clean-up levels are met
(e.g., restoration of groundwater and surface
water). Although physical construction may not
be necessary at some sites, these sites are also
included in this category to fully portray EPA's
progress.
Question #4
Date: 7.
-------
L
Exhibit 4-1
Construction Completion Estimates for Sites on the NPL
Site-Specific
[""I Historical
1993 1994 1995 1996 1997 1998 1999 2000
End of Calendar Year
(A) - Actual Construction Completion Data
Looking at historical trends to determine future rates of construction completions, EPA estimates construc-
tion completion at 63 sites per year, bringing the projected total of sites with construction completion to 665
sites by the end of the calendar year 2000. Site-specific answers from site managers, which may not
account for real world delays that are difficult to predict, project 965 construction completions by the end of
calendar year 2000.
Data Source
1) The source: August 1993 RPM Data Collection
(questions E10 and E13).
2) The full universe of sites addressed by the ques-
tion: The 1,249 final and deleted sites listed on
the NPL as of July 1993.
3) The subset of the universe for which data are
provided: The 1,249 final and deleted sites listed
on the NPL as of July 1993.
Date: 1/26/94
Question *4
-------
uestion #5
Risk Assessments:
This analysis evaluated site risk information from approximately one-half of the sites that have had risk
assessments produced since the passage of the Superfund Amendments and Reauthorization Act
(SARA) and that also have a signed Record of Decision (ROD). For the 216 sites evaluated, exposure
to soil was addressed in 166 risk assessments, exposure to groundwater in 103, exposure to sediment
in 28 and exposure to surface water in 21 site risk assessments. When comparing risk and hazard
levels before and after remediation, both cancer risks and non-cancer hazards show a reduction
following remediation. Individual cancer risks for current as well as future unremediated exposures
between 10~! and 10~3 were most common. Individual cancer risk estimates after remediation were most
frequently reported to range between 10* and 10/s. Non-cancer hazards for current exposures were
most commonly reported to be between 0.1 and less than 100. The reported non-cancer hazard
estimates for sites after remediation were less than 10. While these trends are consistent with
expectations, the levels reported are based on limited analysis that should be refined before definitive
conclusions are drawn.
Overview
Two factors were considered in the selection of risk
assessments because it was not possible to collect and
analyze all available risk assessments . First, a priority
was placed on collecting risk assessments associated
with sites that had a Remedial Investigation/Feasibility
Study (RI/FS) that was started after October 17, 1986
(date of the passage of SARA) and a ROD signed after
September 30. 1990. According to the Comprehensive
Environmental Response, Compensation and Liability
(Act) Information System (CERCLIS), 387 sites fit
these criteria. Second, a priority was placed on the
analysis of sites that were non-Federal Facility sites.
Risk assessments for 216 sites were collected and ana-
lyzed, which corresponds to approximately one-half of
the expected risk assessments. Moreover, the process of
collecting and analyzing risk assessment information is
an ongoing effort.
Risk information is developed to characterize a sue and
support site cleanup decisions. As outlined in the answer
to Question 9. there are several ways that a ROD will
specify that site risk should be addressed. More specifi-
cally, RODs recommend some or all of the following:
• clean up media to risk-based levels based on data
from the baseline or other risk assessment:
• remove/treat contaminated soil;
• clean up groundwater to Maximum Contaminant
Levels (MCLs) or other ARARs; and
» eliminate exposure using engineering or institu-
tional controls.
The use of these other approaches to determining the
need for site cleanups is one reason that risk/hazard
estimates are not generated for all media. Another
reason that risk/hazard estimates may not be reported is
that either the site evaluation does not indicate the
presence of contamination (no estimates were gener-
ated) or risk/hazard estimates were below the reporting
thresholds for this analysis (cancer risk levels of
10"* or greater or a hazard index of 0.1 or greater were
targeted).
Question »S
Date
-------
For each facility for which an RI/FS was initiated after
October 17,1986 and for which a risk assessment has been
completed, please indicate:
• the dated risk assessment completion and whether
addffional risk assessments are anticipated for the
facility.
Exhibit 5-1 summarizes the dates that risk
assessments examined in this exercise were
completed. The reported number of completed
risk assessments was under-reported because the
timing for the data collection effort of this
project did not allow for collection and analysis
of many of the risk assessments. In addition, 7
sites have been omitted from this compilation
because the date of the risk assessment needs to
be verified before reporting. Another 7 sites
were analyzed from fiscal year 1988 (FY 88)
and FY 89. As of the time of data collection
(September 1993), risk assessments were
underway for 45 sites and anticipated for an
additional 74 sites.
• the media addressed (groundwater, surface water,
sediment surface waste or soil).
Of the 216 sites evaluated, 166 site risk assess-
ments addressed exposure to soil, 103 site risk
assessments addressed exposure to groundwater,
28 site risk assessments addressed exposure to
sediments and 21 site risk assessments ad-
dressed exposure to surface water. (No corre-
sponding exhibit).
On the basis of these risk assessments, please quantify:
a. the baseline (current) risk posed by the facility;
b. the future risk projected to be posed by the facfflty if
unremediated; and
c. the future risk projected by the facility when
remediated (residual risk).
Total "facility cancer risk/non-cancer hazard"
was generally not provided. However, total
"facility cancer risk/non-cancer hazard" can be
calculated by combining appropriate individual
scenarios where it is known that the same
person had the potential to be exposed via
multiple scenarios. A total "facility risk/hazard"
was not available for many sites because site
specific cleanup decisions are typically based
upon evaluation of specific media.
a. the basdine (current) risk posed by the facility;
The reported cancer risks for current exposures
at Superfund sites tend to range between 1O5
and 10°. Reported hazard index (HI)
levels for current exposures tended to range
between 0.1 and 100. In some instances, hazard
levels exceeded these values. (No corresponding
exhibit).
b. the future risk projected to be posed by the facility if
unremediated; and
Future uncontrolled risks are similar to current
cancer risk and non-cancer hazard levels exam-
ined. (No corresponding exhibit).
c. the future risk projected by the facility when
remediated (residual risk).
Although a systematic comparison of site
specific risk reduction was not performed, there
is a general tendency for post remediation risk
levels for cancer risk and non-cancer hazard
levels to be lower than current or future
unremediated estimates. Individual future
cancer risk estimates after remediation were
most frequently reported to range between 10*
and 10*. The reported non-cancer hazard
estimates from sites after remediation were less
than 10. Comparing these values with reported
typical values for current and future
unremediated risk estimates suggest reductions
of around two orders of magnitude. Neverthe-
less, some sites were reported to have residual
risks within the risk range (10* to 10°) follow-
ing remediation.
In general, these findings are consistent with overall
expectations for changes in risks and hazards at
Superfund sites. The overall risk/hazard levels are
similar to those reported for other types of sites
associated with hazardous waste.
Date: 1/2&94
Question fS
-------
Exhibit 5-1
Distribution by Fiscal Year (FY) of 216 Completed Risk Assessments
90-,
82
FY90
FY91
FY92
FY93
This exhibit presents a distribution by FY of the 216 sites for which risk information was taken to support this
analysis. Risk information was also obtained from 7 sites where risk assessments were conducted in FY 88
and FY 89. Approximately twice as many risk assessments were expected to have been performed over the
period shown (dates not available). As of the time of data collection (September 1993), risk assessments
were underway for 45 sites and anticipated for an additional 74 sites.
Data Source
1) The source: CERCLIS and Risk Information
Collection Forms.
Question US
Date: 1/26/94
-------
Background Information
What is a baseline risk assessment and how are
the results used?
A baseline risk assessment characterizes current
and future cancer risks and non-cancer hazards
posed by exposure to site contaminants. Cancer
risks and non-cancer hazards are generally
calculated by combining estimates of exposure to
contaminants with toxicity levels.
Risk managers use the results of the baseline risk
assessment or chemical specific standards (such as
Maximum Containment Levels (MCLs) or other
Federal and State Applicable or Relevant and
Appropriate Requirements (ARARs)) to establish
the need to dean up a site. Generally cleanup is
warranted where the baseline risk assessment for
an individual, using Reasonable Maximum Expo-
sure (RME) assumptions, indicates that the risk
exceeds a greater than 1Q/4 lifetime excess cancer
risk or the Hazard Index (HI) for non-cancer hazards
exceeds one.
What is an exposure scenario?
An exposure scenario is comprised of six elements:
a medium (e.g., groundwater, soil, sediment, or
surface water), an exposure route (ingestion,
inhalation or dermal contact), a time frame (current
or future), a location (on-site or off-site), a land use
(residential or industrial) and a receptor population
(e.g., workers, children or trespassers). The
average number of exposure scenarios for a
specific medium is between 5 and 10. Generally,
the scenario that presents the highest risk is used to
define the risk posed by that specific medium.
Specific exposure scenarios combine contaminant
concentration with other parameters such as
contact rate, exposure frequency and duration and
body weight.
What is a cancer risk estimate?
Cancer risk estimates represent a statistical upper
limit probability of excess cancer cases (above
background level) that is associated with environ-
mental contamination. For example, if the risk for a
scenario was 1 x KPthis would present an upper
limit risk of 1 excess cancer case (above back-
ground level) per 10,000 people. The table below
indicates the various probability estimates used.
Cancer Risk
Probability
Estimate
1 X1Q-J
1 x 10'2
1 x 1(T3
1 xKT4
1 x 10'5
1 x 10'6
Excess Cancer
Cases in a Given
Population
1 in 10
1 in 100
1 in 1,000
1 in 10,000
1 in 100,000
1 in 1,000,000
What is a Hazard Quotient (HQ)?
The HQ is the ratio of a contaminant's estimated
exposure level to a reference dose for that contami-
nant (The reference dose is the threshold level
below which it is unlikely for a population to experi-
ence adverse non-cancer health effects). If the
exposure level exceeds the reference dose, then
there may be adverse non-cancer health effects.
What is the non-cancer Hazard Index (HI)
estimate?
The HI is the level below which it is unlikely for a
population to experience adverse non-cancer health
effects (such as nerve damage, birth defects and
liver damage) resulting from exposure to more than
one chemical. The HI is the sum of individual HQs
for each chemical (e.g., if an individual were
exposed to four contaminants in soil, the sum of the
four HQs for these contaminants would provided the
HI estimate for the exposure scenario).
The greater the HI value for a group of contami-
nants in a medium is above 1, the greater the
chance that adverse non-cancer health effects may
result from exposure to that medium.
What is Reasonable Maximum Exposure (RME)?
RME is a measure used to estimate the likelihood of
exposure to contamhants at sites, ft is the maximum
exposure that is reasonably expected to occur at a
site, and is therefore a measure of "high-eno" exposure,
rather than ^average" or "worst-case" exposure.
Date: 1/26/94
Question #5
-------
uestion #6
So/7 Remedies and Principal Contaminants:
As of August 1993, site managers reported 562 Records of Decision (RODs) were signed that address
contaminated soil. These RODs have been signed at 478 sites. Treatment was a principal element
of the selected remedy in 308 (67%) of the RODs. Almost three-quarters of the RODs where treatment
was selected also included a containment technology. The principal contaminants found in the soil at
these sites are lead, arsenic, trichloroethene, chromium, cadmium, toluene, tetrachloroethene and
benzene.
tion) were selected in 6 RODs (8%). The majority of the
RODs (68%) where treatment was a principal element of
the selected remedy also included some form of contain-
ment. (See Exhibit 6-1).
These data show a 28% increase in the number of
treatment remedies selected after the passage of SARA
in 1986. (See Exhibit 6-1).
Where a remedy has been selected for contaminated
soil, indicate the principal contaminants addressed.
Site managers reported that 562 RODs have been signed
to address contaminated soil at 478 sites. At 263 of these
sites, at least one of the chemicals on EPA's list of
principal contaminants is found in the soil and is being
addressed by the remedy selected. At the remaining
sites, the RODs may have been signed recently (i.e..
fiscal year 1993) and the data is not yet available or the
chemicals found at the site are not on EPA's list of
principal contaminants.
The contaminants found most frequently in the soil are
lead (50%). arsenic (40%), chromium (35%),
trichloroethene (35%), cadmium(33%), toluene(30%),
tetrachloroethene (29%) and benzene (27%). (See Ex-
hibit 6-2).
NOTE: The number of contaminants addressed by
RODs is greater than the number of total RODs because
more than one contaminant is generally found in the soil
at a site.
Where a remedy has been selected for contaminated
soil, please indicate the remedy that was selected.
As of August 1993, site managers reported that 562
RODs were signed that address contaminated soil. These
RODs have been signed at 478 sites. (No corresponding
exhibit).
NOTE: The number of RODs signed is greater than the
number of total sites because more than one ROD that
addresses soil may be signed at a site.
Of the 463 RODs where remedy information is avail-
able, site managers reported that 389 RODs that address
contaminated soil were signed post-Superfund Amend-
ments and Reauthorization Act (SARA) (between Octo-
ber 17, 1986 and August 1993). These RODs were
signed at 347 sites. The remedy selected in 277 of these
RODs (71 %) included treatment as a principal element
and containment was selected in 73 RODs (19%). Non-
engineering controls (e.g., institutional controls, moni-
toring, no action) were selected in 39 RODs (10%). The
majority of the RODs (73%) where treatment was a
principal element of the selected remedy also included
some form of containment.
Of the 463 RODs where remedy information is avail-
able, site managers reported that 74 RODs that address
contaminated soil were signed pre-SARA (i.e., prior to
October 17,1986). These RODs were signed at 73 sites.
The remedy selected in 31 of these RODs (43%) in-
cluded treatment (e.g., solidification/stabilization, in-
cineration, soil vapor extraction) as a principal element.
Containment (e.g., off-site iandfilling, surface capping)
was selected in 37 RODs (49%). Non-engineering
controls (e.g., institutional controls, monitoring, no ac-
Questton #6
Date: 1/26/94
-------
Exhibit 6-1
Types of Remedies Chosen to Address Soil Contamination
300-i
250-
200-
g
&
150-
100-
Treatment
Containment
Non-Engineering Controls
277
•1
(24 an
Federal
Before 10M7/86 After 10/17/86
(Pre-SARA) (Post-SARA)
NOTE: The number of RODs is greater than the number of total sites because more than one ROD is often signed at a site.
' Includes 21 RODs where containment was also a component of the remedy.
" Includes 202 RODs where containment was also a component of the remedy.
Background Information
What does the Superfund Amendments and
Reauthorizatjon Act (SARA) say about remedy
selection?
Comprehensive Environmental Recovery, Compen-
sation and LiabSty Act (CERCLA) was amended m
1986 by SARA. Section 121 of SARA required EPA
to select remedes that 'utize permanent solutions
and alternative frBafrnenftechnotogies... to the
maximum extent practicable.'
What are principal contaminants?
Principal contaminants are those chemicals that
represent the most significant threat, in terms of
prevalence or toxkaty, at sites, or represent unique
classes of chemicals (e.g., asbestos or radionu-
dides) that appear at sites.
Data Source
1) The source: August 1993 RPM Data Collection
(questions £32 and E36) with information inte-
grated from the ROD Information Database
System.
2) ThefuU universe of sites addressed by the ques-
tion: The 1,249 final and deleted sites listed on
the NPL as of July 1993 (123 Federal Facilities
and 1,126 non-Federal Facility sites).
3) The subset of the universe for which data are
provided: Those 463 RODs signed to address soil
contamination with available remedy data.
Date: 1/26/94
Question »6
-------
Exhibit 6-2
Sites with Principal Contaminants in the Soil Addressed by Signed RODs
Lead
Arsenic
Chromium (VI)
Trichloroethene
Cadmium
Toluene
Tetrachloroethene
Benzene
Ethylbenzene
Xylenes (mixed)
Nickel
Naphthalene
Mercury
Benzo(a)pyrene
1,1,1-Trichloroethane
Methylene Chloride
Chrysene
Chlorobenzene
Chloroform
DOT
1,2-Dichloroethene
Pentachlorophenol
1,1-Oichloroethane
1,1-Oichloroethene
1,2-Dichloroethane
Vinyl chloride
Dioxin
Dichlorobenzene
DteWrin
Chtordane
PCB1260
1,2,4-Trichlorobeniene
RadtonudidM
alpha-BHC
Carbon tetrachloride
Asbestos
132
20
40
100
120
60 80
Number of Sites
The contaminants found most frequently in the soil are lead (50%), arsenic (40%), chromium (35%),
trichtoroethene (35%), cadmium (33%), toluene (30%), tetrachtoroethene (29%) and benzene (27%).
140
-------
Question #7
Groundwater Adjacent to Superfund Sites:
Most groundwater at or in close proximity to Superfund sites is used as a current source of drinking
water and the majority of groundwater aquifers are classified as potential drinking water supplies.
Future human consumption of groundwater both on-site and downgradient of the plume was assumed
at over one-half of the sites. Approximately 20% of sites with a Record of Decision (ROD) addressing
groundwater contamination relied upon natural attenuation as the sole remedy or in conjunction with
other technologies.
For each facility at which a ROD addressed groundwa-
ter, please provide the following:
a. current use of groundwater adjacent to the facility
(e.g., drinking, irrigation, industrial).
Of the 582 non-Federal Facility sites reporting
RODs signed to address groundwater contamina-
tion, site managers reported that groundwater was
most commonly used as a source for private
domestic wells at 251 sites (43%), while 143 sites
(25%) cite groundwater use for the public water
supply. Of the 40 Federal Facilities reporting
RODs signed to address groundwater contamina-
tion, site managers reported that groundwater was
mostly used for the public water supply at 20 sites
(50%), while 17 sites (43%) cite primary ground-
water use for agricultural purposes. Other uses of
groundwater adjacent to National Priorities List
(NPL) sites are provided in Exhibit 7-1.
NOTE: To ensure a response that would show all
uses of the aquifer in close proximity to the site,
EPA site managers were asked to identify uses of
the groundwater underneath and adjacent to the
site. This ensures that any uses within the site
boundaries, but not directly affected by contamina-
tion, are represented.
current groundwater classification adjacent to the
facility (e.g., sole source, potential source, etc.).
For those sites reporting that groundwater adjacent
to either non-Federal Facility sites or Federal
Facilities has been classified, the majority have
groundwater that is usable or potentially usable as a
drinking water source (i.e.. Class n designation). In
addition. 21% are special groundwaters designated
as Class I. (See Exhibit 7-2). Of the 388 sites where
people are using groundwater for drinking, site
managers reported that 67% were potentially
threatened by a contaminated plume. (No corre-
sponding exhibit).
In addition, many aquifers exchange water with
other important water sources. (See Exhibit 7-3).
c/d assumpoon for future groundwater use and whether
the risk assessment assumed future consumption of
the plume perse or future downgradient consumption
or grounowater.
Of the 582 non-Federal Facility sites reporting
RODs signed to address groundwater contamina-
tion, 328 sites (56%) assumed future human con-
sumption of groundwater both on site and
downgradient (i.e., beyond the extent) of the plume.
' while 65 sites (11%) assumed future consumption of
groundwater only downgradient of the plume.
Sixty-nine (69) sites (12%) assumed future con-
sumption of groundwater only on site. Of the 40
Federal Facilities reporting RODs signed to address
groundwater contamination, 24 sites (60%) assumed
future consumption of groundwater both on site and
downgradient of the plume, while 4 sites (10%)
assumed future consumption of groundwater only
downgradient of the plume. Three (3) sites (8%)
assumed future consumption of groundwater only
on site. (See Exhibit 7-4).
Question #7
Date: 1/2&94
-------
if the remedy relied upon natural attenuation for
cleanup of plume.
Of the 582 non-Federal Facility sites reporting
RODs to address groundwater contamination, 127
sites (22%) relied upon natural attenuation of
contamination as the sole remedy or in conjunc-
tion with other technologies (i.e.. a component of
the remedy). Of the 40 Federal Facilities report-
ing RODs to address groundwater contamination,
8 sites (20%) relied upon natural attenuation of
contamination as a component of the remedy. (No
corresponding exhibit).
NOTE: Preliminary investigations being con-
ducted by EPA to develop groundwater presump-
tive remedies indicate that the survey estimates of
reliance on natural attenuation may be high.
Exhibit 7-1
Uses of Groundwater Underneath and Adjacent to Superfund Sites
fetUw
Groundwater in the vicinity of non-Federal Facility sites is most commonly used as a source for private domestic wells. Groundwa-
ter in the vicinity of Federal Facilities is most commonly used for the public water supply.
NOTE: 1) A single source of groundwater can be used for multiple purposes. For this reason, the percentages shown in the
chart do not add up to 100%.
2) SHemarageK answered Vnknown'(or 10% of non-Fed&alFaalitys^esarHi 5% of Feo^ral Facilities. Answers
were not provided for 7.4% of non-Federal Facility sites and 2.5% of Federal Facilities.
Date: 1/26/94
Question 17
-------
Exhibit 7-2
Groundwater Classifications at Superfund Sites
180-
160-
140-
120-
Number ol Sitei
S 3 8
i ... i ... i .
40-
20-
0-
166
^^ !• Federal Facilities
^^^ ^ (33 with groundwater classification)
| — 1 Non-Federal Facility Sites
I — I (420 with groundwater classification)
94
r
81
60
^•1
56
161
106
H
98
17
10
I I 'V
I ie 1 r^i
Class! Class II Class HA Class UB
Graundvnttr Ctettfficrton*
Class HI
Stats
EPA DttCftotiflfi
111
lib
U
DtacftoBon
SfMcalgmunawitan. Eaherin*>MMHB«(uctsoiy nJ potartal yirtt
Not • pdMMl mm ol dnntoq wtfwid o< bniM btntticBl UN.
CtasticatonabaMdonaStattlaworraguittan. SudiadaMftttonauniqueto
ttw SUM ft wtucft i a tocaua
For those sites reporting that groundwater adjacent to either non-Federal Facility sites or Federal Facilities
has been classified, the majority have groundwater that is usable or potentially usable as a drinking water
source (i.e., Class II designation).
NOTE: Groundwater was either not classified or the classification was unknown at 169 sites. The Super-
fund program classifies groundwater when necessary to determine a remedial action. In some cases, the
groundwater is not classified (e.g., when an alternate water supply is provided). Consequently the number of
sites with a groundwater classification is less than the number of sites with a groundwater ROD.
Question #7
Date: 1/26/94
-------
Exhibit 7-3
Where Does the Affected Aquifer Discharge?
Drinking Water Aquifer
237 Sites, 38%
(21 are Federal Facilities)
Surface Water
386 Sites, 62%
(29 are Federal Facilities) Superfund
Site
Sensitive Ecological
Environment
118 Sites, 19%
(12 are Federal Facilities)
Other 19 Sites, 3%
(1 is a Federal Facility)
None: 28 Sites, 5%
(4 are Federal Facilities)
Aquifers underneath and adjacent to both non-Federal Facility sites and Federal Facilities most often dis-
charge into surface water.
NOTE: The number of affected areas exceeds the number of Superfund sites because one aquifer may
discharge into multiple environs. Site managers answered 'Unknown1 for 72 sites and 'Not Applicable' for 9
sites. Answers were not provided for 24 sites.
Date: 1/2&94
Question #7
-------
Exhibit 7-4
Projected Human Consumption of Groundwater at NPL Sites
Unknown or Not
Provided*
9.6%
Neither On-Site
nor Downgradient
11.1%
Downgradient
Only
11.1% —
On-Site Only
11.6%
60 Sites
(5 are
Federal
Facilities)
69 Sites
(4 are Federal
Facilities)
Both On-Srte
and
Downgradient
352 Sites
(24 are Federal
Facilities)
69
(4 are Federal
Facilities)
(3 are Federal
Facites)
56.6%
* Sites are only included in this category where site managers responded 'Unknown' or did not respond
to assumptions for both on-site and downgradient human consumption.
Data Source
1) The source: August 1993 RPM Data Collection
(questions E37a. E37b, E37c, E38a. E38b, E39,
E40, E42 and E43).
2) The/till universe of sites addressed by the ques-
tion: The 1,249 final and deleted NPL sites as of
July 1993.
3) The subset of the universe for which data are
provided: Those sites with groundwater RODs
signed prior to July 1993: 622 sites and 745
RODs, which include 582 non-Federal Facility
sites reporting 690 RODs and 40 Federal Facili-
ties reporting 55 RODs.
Question #7
Date: 1/26/94
-------
Background Information
There have been 690 RODs signed to evaluate
contamination of groundwater at 582 non-Federal
Facility sites and 55 RODs signed to address
groundwater contamination at 40 Federal Facilities
with groundwater contamination.
How is groundwater classified?
Groundwater is generally classified according to its
quality, quantity and intended use. The Federal
classification scheme distinguishes between
groundwaters that are currently used for drinkng
water purposes, those that are potentially usable for
drinking water and those that, due to poor quality or
insufficient quantity, are not suitable for drinking
water purposes. States also may have their own,
unique classification scheme.
What is natural attenuation?
Natural attenuation refers to the processes of
biodegradation, dispersion, dilution and absorption
of contaminants found in groundwater. In limited
situations where the chemical and biological
conditions of the contaminated aquifer are favor-
able, natural attenuation may be capable of reduc-
ing contaminant concentrations to acceptable
heath-based levels over time. However, for natural
attenuation to be effective, it must generally be
preceded by source removal or control measures
and other active forms of remediation.
When is a water supply considered to be a
public water supply?
EPA considers water supplies to be public if the
water system has at least 15 service connections or
serves an average of at least 25 year-round
residents. EPA regulations under the Safe Drinking
Water Act apply to all public water supplies. Certain
EPA drinking water standards also apply to water
systems that regularly serve at least 25 of the same
people for more than 6 months per year (e.g., rural
schools).
Date: 1/2&94
Question *7
-------
Question #8
Groundwater Contamination:
As of August 1993, site managers reported 745 Records of Decision (RODs) were signed that address
groundwater contamination. These RODs were signed at 622 sites. The primary objective of RODs
at the vast majority of the sites (84%) is to restore the groundwater to beneficial use.
Based on the September 1993 Dense Non-Aqueous Phase Liquid (DNAPL) survey results, EPA
estimates that there is a medium to high likelihood that DNAPLs will be present at almost 60% of all
National Priorities List (NPL) sites.
For each facility where a remedy has been selected for
groundwater, please indicate the remedy that was selected.
Site managers reported 745 RODs for 622 sites that
address ground water contamination have been signed as
of August 1993. (No corresponding exhibit).
EPA selects remedies to address groundwater contami-
nation that meets one or more of the following three
objectives (in priority order): 1) restoration of the
groundwater to beneficial use through the use of treat-
ment technologies or natural attenuation: 2) contain-
ment of the contaminated groundwater through the use
of subsurface barriers (e.g., slurry wall); or 3) controlling
or limiting direct exposure to the contamination (e.g..
providing an alternate water supply, closing wells).
Remedy data are available for 501 of the 622 sites with
RODs that address groundwater. Of these 501 sites, the
highest objective to be achieved at 423 sites (84%) is
restoration of the groundwater to beneficial use. At least
25% of these 423 sites include the achievement of one
additional objective, such as providing an alternate wa-
ter supply or containing a portion of the contaminated
groundwater aquifer. In addition, 4 sites (1 %) have as
their highest objective to contain the contaminated
groundwater; and 74 sites (15%) have the sole objective
to limit/control exposure. (See Exhibit 8-1).
At 80% of the sites, remedies were selected that include
pumping and treating the contaminated groundwater.
NOTE: The number of RODs signed is greater than the
number of total sites because more than one ROD that
addresses groundwater may be signed at a site.
Exhibit 8-1
Objectives of Groundwater
Remedies at Sites
Containment
4 Sites
(1%)
15%
Of the 501 sites where remedy information is
available, 84% have as their highest objective
restoration of the groundwater to beneficial use.
NOTE: During implementation of a specific
technology to restore the groundwater. EPA
may also take action to limit exposure to the
contamination.
Question #8
Date: 7/2694
-------
For each facility where a remedy has been selected for
groundwater, please indicate whether DNAPL contamina-
tion is highly likely.
The study released in September 1993, titled "An Evalu-
ation of the Likelihood of DNAPL Presence at NPL
Sites." surveys existing data for sites to retrospectively
determine the potential for DNAPLs to be present in the
groundwater. In the study, EPA estimates that approxi-
mately 5% of NPL sites will exhibit definite DNAPL
presence via a visual observation and 52% of sites have
a medium to high likelihood of DNAPL presence.
Twenty-seven percent (27%) of sites have a low poten-
tial: and 16% of the sites are unlikely to have DNAPLs
present. The study shows that certain factors, such as site
use and site contaminants, correlate well with the pres-
ence of DNAPLs. (See Exhibit 8-2).
Exhibit 8-2
DNAPL Contamination in Groundwater
20*
NOTE This graphic reflects the entire NPL as extrapolated
from a focused sample of sites in five ot the ten EPA
Regions.
For each groundwater remedy where DNAPL contami-
nation is highly likely, please provide the following
information:
a. Was the ROD(s) involving groundwater signed
before or after EPA's May 1992 guidance on
DNAPL sites?
The September 1993 DNAPL study focuses on
302 sites, 185 of which have signed RODs that
address groundwater. The DNAPL study further
indicates that at 97 of these sites, the presence of
DNAPLs is definite or highly likely. Site manag-
ers reported that 135 RODs that address ground-
water have been signed at these sites. Of these,
only 19 RODs (14%) have been signed since EPA
issued the new DNAPL guidance in May 1992.
One ( 1 ) of these RODs was signed at a Federal
Facility. The remaining 1 16 RODs were signed
prior to May 1992. Two (2) of these RODs were
at Federal Facilities. (No corresponding exhibit).
1 ) Sources: 1 ) " An Evaluation of the Likelihood of
DNAPL Presence at NPL Sites" (NTIS #PB93-
963343, September 1993); 2) EPA Analysis of
Technical Impracticability Waivers. (Internal
Document. June 1993); and 3) RPM Data Collec-
tion (questions E32, E36, E46 and E47 with
information integrated from the ROD Information
Database System).
2) The full universe of sites addressed by the ques-
tion: The 1 ,249 final and deleted sites on the NPL
as of July 1993 (123 Federal Facilities and 1,126
non-Federal Facility sites).
3) The subset of the universe for which data are
provided: The 501 sites listed on the NPL with
RODs that address groundwater contamination
and where remedy data are available.
Date: 1/26/94
Question #8
-------
b/c. Did the selected remedy seek to return groundwater
to drinking water standards and/or did the selected
remedy have containment pumping as its goal?
EPA recently issued guidance on the limited
exceptions to the Agency's primary objective of
returning contaminated groundwater to beneficial
use. This guidance states that "where it is techni-
cally practicable to contain the long-term sources
of contamination, such as the DNAPL zone, EPA
expects to restore the aqueous contaminant plume
outside the DNAPL zone to required cleanup
levels." In addition, the Agency expects to
contain or remove the DNAPLs source at sites.
Consequently, at some sites, more than one
response may be appropriate to remediate ground-
water contamination. Based on the conditions
surrounding the source of the contamination and
the nature of the dissolved plume, a remedy may
include pump and treat, containment and/or
natural attenuation. Particularly where free-phase
DNAPLs are present, containment pumping
facilitates restoration of the dissolved plume.
Of the 135 RODs that address groundwater at
sites where DNAPL presence is definite or highly
likely, 87 RODs (64%) have a goal of returning at
least some portion of the contaminated groundwa-
ter to drinking water standards. Two (2) of these
remedies are at Federal Facilities. In addition, site
managers report 103 RODs (76%) selected
containment pumping as a component of the
remedy selected. Three (3) of these RODs were at
Federal Facilities.
Of the 19 RODs signed since the issuance of the
new DNAPL guidance in May 1992,12 RODs
(63%) have a goal of returning at least some
portion of the contaminated groundwater to
drinking water standards, and 16 of the RODs
(84%) include containment pumping as a compo-
nent of the remedy selected. (See Exhibit 8-3).
Exhibit 8-3
Sites With DNAPL Containment Remedy
Containment pumping is a common reniertedtoa
-------
d. Did EPA invoke a technology feasibility waiver to avoid
applying ARARs to the DNAPL cleanup?
From 1986 through 1992. EPA addressed techni-
cal impracticability at 39 NPL sites. EPA waived
cleanup standards (ARARs) at the time of the
ROD at 13 sites because achieving the standards
was technically impracticable based on site
conditions. Nine (9) of these waivers were for
sites where the presence of DNAPLs may have
precluded restoration of groundwater to the
cleanup standards in all or part of the contami-
nated aquifer.
EPA also signed 23 RODs during this period that
contained a contingency provision to waive
groundwater ARARs due to technical impractica-
bility. Such a contingency allows the Agency to
invoke an ARARs waiver in the event that new
information, obtained after implementation of the
selected remedy, indicates that achieving cleanup
standards is technically impracticable. At least 10
of these "contingency waivers" were related to
DNAPLs.
In addition, EPA included language waiving
ARARs due to technical impracticability in three
ROD amendments. At least one of these waivers
was related to DNAPLs. ROD amendments are
issued by EPA to document a fundamental change
in a remedy selected in a ROD based on informa-
tion obtained after the ROD was approved. A
ROD amendment may not be required if such a
change was anticipated with contingency lan-
guage in the original ROD. More than one-half of
the 39 technical impracticability determinations
were issued subsequent to EPA's May 1992
DNAPL guidance. (No corresponding exhibit).
Background Information
What are free-phase Dense Non-Aqueous Phase
Liquids (DNAPLs)?
DNAPLs are contaminants that do not readily mix with
and are more dense than water in their uncfluted form.
DNAPLs include a wide range of chemical types and
mixtures, inducing chlorinated solvents, creosote, coal
tars, PCBs (potychlomated biphenyts) and some
pesticides. Chlorinated solvents, the most prevalent
DNAPLs, can sink to great depths and migrate over
large distances from their release port. As a result
DNAPLs can be dfficutt to locale in the subsurface and
are often undetected. As DNAPLs migrate through the
subsurface, a portion becomes trapped in the soil pore
spaces or fractures and the remainder can continue to
migrate or form pools in the soior aquifer matrix. The
portion of DNAPLs that can continue to migrate is cated
freephase DNAPLs. DNAPLs make groundwater
cleanup more dfficutt because, even though they donot
mix, they stowty release deserved chemicals over a long
tone, forming a plume of contaminants in the groundwa-
ter adjacent to the DNAPLs.
What are Applicable or Relevant and Appropriate
Requirements (ARARs)?
ARARs are State or Federal laws, regulations, stan-
dards, requirements, criteria, or finitations that are
tegaty applicable or relevant and appropriate to the
contaminart of cox^ or deanup action beirgt^^
the site. EPA is required to consider all ARARs when
selecting a remedy for a site.
What to a Technical Impracticability ARAB Waiver
(Tl ARAR Water)?
Six types of ARAR waivers are identified in Section 121
of the CERCLA, as amended One of these provisions
alowsARArlstobewarvedifEPAfirKisthatVxxnpli-
ance with such requirements is technically impracticable
from an engineering perspective.' A decision to waive a
groundwater cleanup standard on the grounds of
technical impracfcabffity, or a Tl ARAR waiver, is
rted in a Record of Decision (ROD) along with
an explanation of why me ARAR carrot be attained.
(Part d of this question refers to technical irnpracfcabifity
ARAR waiver as a technical feasfcity waiver, however,
tterorTecttemiirwtooyistecruik^
ARAR waiver).
Date: 1/26/94
Question *8
-------
uestion #9
Cleanup Standards and Soil Exposure Assumptions:
The most affected media at Superfund sites are soil, sediment and grounawater. For the sites where
groundwater is contaminated, Federal and State Applicable or Relevant and Appropriate Require-
ments (ARARs) are often the basis for cleanup for most of the principal contaminants. For most sites.
soil cleanup levels are established to protect groundwater at the site. Risk assessments are driving
cleanup levels in relatively few situations.
Please provide the complete set of cleanup standards
(contaminant by contaminant, for each media) used at the
facility. Indicate whether the standard was based on risk
assessment, MCL, state standard, or other (indicate what
other).
Exhibits 9-1 and 9-2 show the total number of sites where
particular chemicals were found and the number of sites
where the respective bases forcleanup standards were used
toestablish cleanupconcentration levels for various chemi-
cals. These exhibits present data for 42 specific chemicals
and the category of radionuclides that represent the most
significant threats at sites in either soil or groundwater. The
42 chemicals were chosen because of their prevalence and
toxicity, or because they represent unique classes of chemi-
cals that appear at sites (e.g., asbestos, radionuclides).
These data are taken from a universe of 194 sites for which
detailed risk and cleanup level data were taken from site
characterization documents and Records of Decision
(RODs) (from Question 5). Chemicals are listed only for
media in which they have been found.
Not all chemicals are found at every site. Furthermore.
cleanup standards are not necessarily developed for every
contaminant at every site (e.g., a chemical may be present
at a site below a level of concern: therefore, cleanup levels
would not be developed for that chemical at that site).
However, at some sites, chemical standards were listed for
every chemical found at that site, not just those found to be
posing a significant threat at that site. Also, a particular
chemical may have a cleanup concentration level with
more than one basis (e.g., a State ARAR and a Federal
MCL) established at the same concentration level, and both
serve as the basis of cleanup.
Where a cleanup standard has been established for soil
based on a risk assessment initiated after October 17,1986.
please indicate the date of completion of the risk assess-
ment and each of the exposure assumptions used for each
cleanup standard.
At 33 of the 194 sites, soil cleanup standards were based on
a risk assessment that was initiated after October 17. 1986
with a ROD signed after September 30. 1990. These 33
sites do not include sites where soil cleanup levels were
based on modeling from groundwater MCLs, Maximum
Contaminant Level Goals (MCLGs) or other standards
applicable to soil concentration where soil contaminants
leach to groundwater.
Risk-based soil cleanup standards for sites may be based on
more than one exposure route. For example, ingestion and
inhalation of dust-blown soil may be combined to form a
composite soil exposure scenario that serves as the basis for
setting risk-based cleanup levels. For answers to the
remainder of this question, soil cleanup standards for sites
may be based on more than one set of exposure assump-
tions.
NOTE: Because more than one set of exposure assump-
tions (i.e.. exposure route, durations orfrequencies) may be
considered in developing a soil cleanup level, the number
of times different exposure assumptions appear may be
greater than the total universe of sites. {No corresponding
exhibit!.
Quest/on #9
Date: 1.V&94
-------
a. Was the driving factor establishing the standard soil
ingestion, leaching to groundwater or other routes of
exposure, (please indicate what other, e.g., dermal,
inhalation)?
The most common exposure routes of contaminants
through the soil medium used to determine soil cleanup
standards are ingestion, dermal exposure and soil
inhalation.
Out of a total universe of 33 sites, the ingestion route
was used in establishing cleanup levels at 28 sites;
dermal contact was used in 19 sites: inhalation was
used in 14 sites; ingestion of contaminated food was
used in 3 sites; and another exposure route was used at
1 site. {No corresponding exhibit).
b. What are the number of total years and number of
days per year of exposure to the facility, broken down
by age of exposed individual where appropriate?
At 24 out of 33 sites, exposure to children (6 years or
younger) was determined to be relevant. At 4 out of
these 24 sites, exposure was assumed to occur over a
period of 3 years or less for children. At 20 out of 24
sites, 4 to 6 years of exposure was assumed. (The
frequency of exposure was assumed to be greater than
200 days/year at 15 of 24 sites, between 101 and 200
days/year at 5 sites, and less than 100 days/year at 4
sites.)
For adults, defined as older than 6 years, at all 33 of the
sites, 17 or less years of exposure was assumed; at 27
of 33 sites between 18 and 30 years of exposure was
assumed; and at 2 of 33 sites greater than 30 years of
exposure was assumed. (The frequency of exposure
was assumed to be less than 200 days/year at 32 of 33
sites, between 101 and 200 days/year at 17 of 33 sites
and 100 or less days/year at 13 sites.)
NOTE: Because more than one duration of exposure
was considered to be important at some sites, the sum
of all durations of exposure for adults is greater than the
universe of sites. (No corresponding exhibit).
c. What is the amount of soil ingested per day of expo-
sure, broken etown by age of exposed individual where
appropriate?
At 23 of 24 sites where exposure to children was
determined to be relevant, children were assumed to
ingest 200 mg/day of contaminated soil. At 1 of 24
sites. 100 mg/day was the assumed ingestion rate.
Adults were assumed to ingest less than 1 00 mg/day at
1 1 of 33 sites. At 30 of 33 sites, adults were assumed
to ingest between 100 and 120 mg/day. At 7 of 33 sites,
adults were assumed to ingest 200 or greater mg/day.
(No corresponding exhibit).
cL Was exposure to contaminated soil assumed to occur
to maximum concentrations found at the facility,
average concentration, or other (indicate what other).
In assessing risks from soil contamination, the mea-
sure of concentration used in the baseline risk assess-
ment was the reasonable maximum exposure (RME)
at 23 of 33 sites, maximum concentration at 9 of 33
sites and another measure of concentration at one of 33
sites. (See Background Information for discussion of
different measures of soil concentration). (No corre-
sponding exhibit).
e. Were any of the contaminants used to calculate risk
assumed to degrade in soil over time (thereby decreas-
ing exposure)?
At only 1 of 33 sites, some contaminants are assumed
to degrade over time. (No corresponding exhibit).
NOTE: Degradation of contaminants can be very
uncertain and difficult to estimate. Many contami-
nants, such as metals and complex organic com-
pounds, do not degrade at all or degrade extremely
slowly.
1) The source: August 1993 Human Health and Soil
Ingestion Data Collection Forms.
2) The fall universe of sites addressed by the question:
1 ,249 final and deleted sites listed on the NPL as of
July 1993.
3) The subset of the universe for which data are
provided: The 33 sites where an RI, FS or a com-
bined RI/FS was started after October 17. 1986, a
ROD addressing soil contamination was signed after
September 30, 1990, a risk assessment has been
completed and soil cleanup goals are based on a
completed risk assessment _
Date: 1/2&94
Question #9
-------
Exhibit 9-1
Basis of Standards for Principal Contaminants in Groundwater at 103 Sites
Contaminant
1,1 Dichloroethene
1,2 Dichloroethane
1,2 Dichloroethene
Arsenic
Benzene
Benzo (a) pyrene
BHC, alpha
Cadmium
Carbon Tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
DDT
Dichlorobenzene
Dieldrin
Dioxin
ithylbenzene
Lead
Mercury
Methylene Chloride
Naphthalene
Nickel
Pentachlorophenol
Radionudides
Tetrachloroethene
Toluene
Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes
Number of Sites per Basis of Cleanup Standard
MCL
".
21
7
2
14
7
2
7
12
4
1
1
10
9
9
4
1
4
4
1
6
17
10
29
1
MCLG
1
1
1
2
1
1
RCRA
Land Disposal
1
1
1
Risk
Assessment
1
1
2
2
1
2
1
1
4
1
1
1
1
2
State
ARAR
3
1
5
5
6
6
6
•
1
14
9
6
3
3
3
13
1
2
24
12
Other
2
1
6
3
3
1
2
1
4
21
1
1
4
2
4
9
3
4
7
MCL • Maximum Contaminant Level
MCLG - Maximum Contaminant Level Goal
RCRA - Resource Conservation and Recovery Ad
ARAR - Applicable or Relevant and Appropriate
Requirements
NOTE: A particular chemical may have a cleanup concentration level with more than 1 basis (e.g., a State
ARAR and a Federal MCL) established at the same concentration level, and both serve as tfie basis
for cleanup.
Question 19
Date: 1/26/94
-------
Exhibit 9-2
Basis of Standards for Principal Contaminants in Soil at 166 Sites
Contaminant
1,1 Dichloroethene
Arsenic
Asbestos
Benzene
BHC, alpha
Cadmium
Chlordane
Chlorobenzene
Chloroform
Chromium
Chrvsene
DDT
Dieldrin
Dioxin
Ethvlbenzene
Lead
Mercury
Methvlene Chloride
Naphthalene
Nickel
Radionuclides
Tetrachloroethene
Toluene
Trichloroethene
Vinvl Chloride
Number of Sites per Basis of Cleanup Standard
MCL
1
1
1
1
1
1
1
MCLG
1
RCRA
1
1
1
1
1
1
1
1
1
RCRA
Land Disposal
3
5
^
2
Clean Water
Act
1
1
1
Risk
Assessment
12
2
3
1
1
1
2
2
2
1
8
5
3
1
1
2
State
ARAR
2
3
1
1
1
3
4
2
1
1
3
2
Other
2
1
4
1
1
5
15
1
1
4
1
1
4
2
1
MCL • Maximum Contaminant Level
MCLG - Maximum Contaminant Level Goal
RCRA - Resource Conservation and Recovery Act
ARAR - Applicable or Relevant and Appropriate
Requirements
NOTE: A particular chemical may have a cleanup concentration level with more than 1 basis (e.g., a State
ARAR and a Federal MCL) established at the same concentration level, and both serve as the basis
for cleanup. Generally, the baseline risk assessment basis for the cleanup level applies to sites
where direct contact (inhalation, dermal contact, or ingestion) are actual or potential threats. In
some situations, it may include modeling of contaminants leaching from soil to groundwater. The
MCL, MCLG, and 'other* basis for cleanup standards reflect the threat posed by contaminants
leaching from soil to groundwater. "Other" also includes partitioning of contaminants from sediment
to surface water and application of ambient water quality criteria in surface water.
Date: 1/2&94
Question #9
-------
Background Information
What are cleanup standards?
Cleanup standards, developed by State or
Federal agencies, are concentrations of con-
taminants that are considered acceptable (i.e.,
do not pose a threat to potential receptors): In
the Superfund program, many cleanup stan-
dards are adopted from other Federal and State
environmental laws. For example, Maximum
Contaminant Levels (MCLs) and MCL Goals
(MCLGs) from the Safe Drinking Water Act have
been adopted as standards for Superfund.
States can have their own standards which may
be more stringent than Federal standards.
Some States have also developed cleanup
standards for soil. Other Applicable or Relevant
and Appropriate Requirements (ARARs) also
may provide cleanup levels.
What is a risk assessment?
A risk assessment characterizes risks, either
actual or potential, posed to human health and
the environment by site contaminants. Site
managers use the results of the assessments to
help determine whether a cleanup is warranted
and the appropriate remedies for redressing the
risks posed by the site.
How are populations categorized for risk
assessment?
Risk assessment assumptions are often catego-
rized into child and adult age groups. These
groups account for significant differences in
behavior, activities and body weight that would
affect exposure to contaminants. Risk asses-
sors take into consideration that these situations
may change, for example, children growing into
adults while living near a Superfund site.
What are different exposure concentrations?
EPA guidance states that an arithmetic average
soil concentration should be used in all
Superfund exposure/risk assessments. How-
ever, the number of samples collected at each
site varies considerably, and over the years
assessments have been submitted to the
Agency with averages based on a limited
number of samples. As a way to deal with the
uncertainty involved in calculating the "true*
average soil concentration at a site (especially
with limited data sets), the 95 percent upper-
confidence limit (UCLgj) on the arithmetic mean
is preferred.
This term is referred to here as the reasonable
maximum exposure (RME) concentration. In
cases where the data are limited or there is
extreme variability in the measured (or modeled)
data, the UCL^ can be much higher than the
highest concentration measured at the site. If
additional samples cannot be collected, the
highest measured (or modeled value) is often
used as a default to represent the exposure
point concentration. However, the true site
mean may actually be n/gnerthan this maximum
value, because the UCL^ indicates that a higher
mean is possible.
Question #9
Dale: 1/26/94
-------
uestion #10
Land Use:
Less than one-half (44%) of National Priorities List (NPL) sites have a single on-site land use. The most
common current land uses on sites are industrial, none (e.g., abandoned) and commercial. In addition,
15% of the sites currently have residents living on site.
More than three-quarters (76%) of sites have a mixed land use surrounding the site. Seventy-nine
percent (79%) of sites have residential land use surrounding them. About 72.8 million people live within
4 miles of a site.
In the future, one-half of the sites are expected to have a single land use. Land uses at sites are
expected to be industrial, residential and commercial. In the future, land uses adjacent to sites are
expected to be primarily residential.
b. current adjacent land use.
Seventy-six percent (76%) of sites have mixed land
use (two or more uses) surrounding the site, while 23 %
have a single land use. Of the 1.245 sites repotting.
only one is surrounded by land that is not in use. (No
corresponding exhibit).
Of the 1.245 sites reporting current land uses surround-
ing the site, the majority are residential, commercial
and agricultural. (See Exhibit 10-2 for a comparison
of all current on-site and surrounding land uses).
NOTE: In this survey, land use for areas surrounding sites
was defined as any use in 'close proximity" to sites. This
term allows for more than simply abutting or adjacent land
uses.
c. if current adjacent land use includes residential use,
number of people living near the site.
A preliminary review of Census data suggests approxi-
mately 72.8 million people living within 4 miles from
the center of 1,193 sites. The method employed by
Supertund (see Background Information) does not
provide an accurate and reliable estimate for very small
geographic areas. (No corresponding exhibit).
NOTE: Due to the nature of the land use questions, site
managers may not have been able to answer all questions
for each site. There are four types of land use portrayed
(current site land use, current land use surrounding the site.
expected future land use and expected future land use
surrounding the site); the number of responses differs for
each.
Please provide the following information:
a. current land use of the facility perse.
Forty-four percent (44%) of sites currently have a
single land use; 29% have no active current land
use: and 26% have two or more current land uses
based on the 1.247 sites reporting (out of all 1.249
sites). Current site use is 'Unknown' at 1% of the
NPL sites reporting.
Of the 551 sites reporting a single on-site land use,
the most frequent uses are other (e.g., closed
landfill, wetlands), industrial and commercial. Of
the sites reporting multiple on-site land uses, the
most frequent uses are industrial, commercial and
residential. (See Exhibit 10-1 for a comparison of
current and future expected single and multiple on-
site land uses).
Combining all (single and multiple) current on-site
land uses reported, the most frequent uses are
industrial, none, (e.g.,abandoned) and commercial.
(See Exhibit 10-2 for a comparison of all current
on-site and surrounding land uses).
Question *10
Date: 1/2&94
-------
d. assumption for future land use of the facility perse
(e.g., industrial, residential, etc.).
Fifty percent (50%) of the sites are expected to have a
single use in the future; 28% are expected to have two
or more uses and 13% are not expected to be in use
based on the 889 sites reporting (out of all 1.249 sites).
The future site use is 'Unknown' at 9% of sites.
Of the 446 sites reporting a single future land use on
site, the most frequent uses are expected to be indus-
trial, other (e.g., closed landfills, wetlands) and residen-
tial. Of the 245 sites reporting multiple future land uses
on site, the most frequent uses are residential, commer-
cial and industrial. (See Exhibit 10-1 for a comparison
of current and future expected single and multiple on-
site land uses).
Combining all (single and multiple) future on-site land
uses reported, the most frequent uses are expected to be
industrial, residential and commercial. (See Exhibit
10-3for a comparison of all future expected on-site and
surrounding land uses).
Exhibit 10-1
On-Srte Land Uses at Sites
Current
Future Expected
NoUnd
UM
One Land Use
Unknown
OmLwdUse
Two or Mora
(Muttipte)LandUMS
Two or More
(Multiple) Und Use*
Current
Future Expected
Induttntf
Comma*
Otar*
A(HH«A.W^
AyWm
Eduabanri
SinoMteSttH IhMpMJtt Tot* Srtn «tt Ejch UM
170
117
208
19
23
13
1
214
200
81
173
115
56
54
384
317
289
192
138
69
55
Murtriri
nt*tH**
CUIHWUJI
OttW
RirmrtmiH
Agricuftnl
EAafem
SngMJMSttn KUbpto-Uw Total SttH Mft ttch Uw
159
69
62
98
42
15
1
145
162
152
32
87
47
28
304
231
214
130
129
62
29
* The 'Other1 category includes: closed landfills, military, undeveloped lands, wetlands and wildlife habitats.
NOTE: Current on-site land uses represent data from 1347 sites responding while future expected on-site land uses represent
data from 889 sites responding. These land-use numbers add up to more than the total number of sites reporting because there
may be more than one current or expected land use at a given site.
Date: 1/2&94
Question HO
-------
e. assumption for future adjacent land use (industrial,
residential, etc.).
Seventy-three percent (73%) of sites are expected to
have mixed uses surrounding the sites, while 24%
will have a single land use surrounding the site based
on the 881 sites reporting (out of all 1,249 sites).
Only 1 % expect to have no land use surrounding the
site. Future surrounding- land use was reported as
'Unknown' at 2% of the sites. (No corresponding
exhibit).
The expected future land uses for areas surrounding
the majority of sites are residential, industrial and
commercial. (See Exhibit 10-3 for a comparison of all
future expected on-site and surrounding land uses).
Exhibit 10-2
Current On-Site and Surrounding Land Uses of Sites
On-Site Surrounding
Industrial
None
(e.g., abandoned)
Commercial
Other
Industrial
1 None (e.g., abandoned)
Residential
Educational
* The 'Other* category includes: closed landfills, military, undeveloped lands, wetlands and wildlife habi-
tats.
NOTE: Of the 1,249 final and deleted NPL sites (123 Federal Facilities and 1,126 non-Federal Facility sites),
on-site land uses reflect data from 1,247 sites reporting while surrounding land uses reflect data from 1J>45
sites reporting. These current land-use numbers add up to more than the total number of sites reporting
because there may be more than one land use at or surrounding a given site.
Question HO
Data: 1/2&94
-------
Exhibit 10-3
Future Land Use of Sites
On-Site Surrounding
Industrial
Other-
369
Industrial
652
363
Residential
Commercial
321
Recreational
None (e.g., abandoned)
Agricultural
Educational 29
7 None (e.g., abandoned)
Agricultural
Educational
* The 'Other1 category includes: closed landfills, military, undeveloped lands, wetlands and wildlife habi-
tats.
NOTE: Of the 1,249 final and deleted A/PL sites (123 Federal Facilities and 1,126 non-Federal Facility sites),
on-site future land uses reflect data from 889 sites reporting while surrounding future land uses reflect data
from 881 sites reporting. These expected land-use numbers add up to more than the total number of sites
reporting because there may be more than one expected land use at or surrounding a given site.
SuDDJementellnfo^
Currently, 35% of the sites are totally or partially aban-
doned. In the future, over one-quarter of these sites will
continue to be abandoned, but an almost equal number
will have residential (25%) or industrial (24%) site uses.
(No corresponding exhibit).
Site managers reported the future land use at 252 of the
sites where the current land use is industrial. The
majority of these sites (72%) will continue to have an
industrial land use in the future. Other frequently re-
ported future land uses at these sites include commercial
(73 sites) and residential (64 sites). (No corresponding
exhibit).
Of the 231 sites that are expected to have a future
residential land use. the most frequently reported current
land uses are residential (135 sites), commercial (128
sites) and abandoned (115 sites). (No corresponding
exhibit).
Date: 1/26/94
Question tW
-------
Background Information
Assumptions used to provide population
information.
The population information is based on a
preliminary review of U.S. Census Bureau data.
U.S. Census Bureau data is based on units
(called 'blocks') that vary in configuration and
area! extent especially from urban to rural
areas. Census Bureau data identify the centroid
of each 'block* (around which there is a uniform
population count). EPA has utilized the data
from the central point at the NPL site and
eliminated the potential for double counting
where NPL sites are in close proximity to each
other. Due to the number of assumptions and
the difficulty of comparing Census 'blocks' with
NPL site boundaries, accurate and reliable
population data within 1/4 mile are unavailable
at this time.
What is the Graphic Exposure Modeling
System (GEMS)?
GEMS is an automated population estimation
system which relates area population to a single
point. It was developed by EPA's Office of
Toxic Substances to estimate potential popula-
tion exposure. The system can account for
"double counting" of populations within a given
proximity to more than one site. (In this ques-
tion, the system was used to estimate the
population within 4 miles of facilities).
DatoSourre
1) The source: August 1993 RPM Data Collection
(questions E9a, E9b and E35), CERCLIS and GEMS
database.
2) The full universe of sites addressed by the question:
The 1,249 final and deleted sites on the NPL as of
July 1993 (123 Federal Facilities and 1,126 non-
Federal Facility sites).
3) The subsets of the universe for which data are
provided: 1,247 sites responded with current land
uses; 1,245 sites responded with current land uses for
surrounding areas; 889 sites responded with expected
future land uses; 881 sites responded with expected
future land uses for surrounding areas; and GEMS
information correlated to the latitudes and longitudes
at 1,193 sites.
Question IW
Date: 1/26/94
-------
uestion #11
ATSDR Recommendations and Follow-Up:
ATSDR has initiated follow-up studies for 15% of the sites for which the need for follow-up hearth
studies has been identified.
Please identify whether ATSDR has indicated that a
more in-depth study under Section 104(i) is needed
after the health assessment is completed. Indicate for
each such facility whether such a study is planned,
underway, or completed and identify the type of study.
SARA Section 104(i) requires ATSDR to complete a
Public Health Assessment within one year of the date
that a site is proposed to the National Priorities List
(NPL). ATSDR has completed at least one Public Health
Assessment for over 1,249 NPL sites.
Background Information
What is the Purpose of an ATSDR Public
Health Assessment?
ATSDR Public Health Assessments assist in
determining whether actions should be taken to
reduce human exposure to hazardous sub-
stances from a site, whether additional informa-
tion on human exposure is needed, and whether
specific health follow-up studies should be
undertaken for a site. Follow-up health studies
may include epidemiological studies, establish-
ing a registry of exposed individuals, establish-
- ing a health surveillance program or other public
health related activities.
Data Source
1) ATSDR's HazDat database and Public Health
Actions Tracking System.
Exhibit 1-1 shows the types of studies conducted (some
sites have more than one study). Exhibit 1-2 lists the 56
NPL sites (some sites are included in more than one
study) at which ATSDR has initiated health studies.
These studies include biological indicators of exposure
studies, disease and symptom prevalence studies, regis-
tries (trichloroethylene, dioxin and benzene), epidemio-
logical studies, and other studies. Twelve (12) studies
are complete and 8 studies (at 5 sites) have completed the
development of a protocol. In addition, since September
1990, ATSDR has reviewed over 500 NPL sites: these
reviews have identified the need for approximately 200
health studies involving 140 sites.
Exhibit 11-1
Types of Health Studies Initiated
NOTE The number of health studies is greater than the
total number of sites because more than one study may
be conducted at a site.
Question tn
Date: 1/26/94
-------
Exhibit 11-2
Health Studies Initiated by ATSDR
Site Name
MMttatn PeeticidM Dump
ACHE Solvent Redainmg Inc
AUied Corp Kaitmazoo Pit
Anderson Development Co
But) A McGure
BetoitCorp
Hot on Nobei fnc
Brio fWinwy Co, die.
Bunfcar HiU Mining * Metallurgical
Cmpta
Bunker HHI lining 4 Uotallurgicil
Cmptx
Byron Salvage Yard
Canon River Mercury Site
Count Cdy-Clear Creek
CherohM County, Kama*
ComnwnoiiMnl Bay-South, Takoma
Channel
WWIHlWH^ntHH BvySOUttl* TAuHYiA
Channel
CONRAIL Haityard Elkhart
MHraiuBMr winy AAUMMwA rani
Crystal Chwniul Co.
Qwml HotoralCtntrai Faundvy Ore.
Gntfit* Air Fora tat
Hantord - 100-AfM (DOE)**
Hanford nowkrw (DOE)"
Hwford 2MMTM (DOE)*1
Htntorr] 300-Arat (DOE)**
UuluMiUi ueau Lai
MmtMt LMd Co (ILCO)
USiHt Ebdrical IMHibM
LipinLindHI
CERCUSNo.
NCD980643346
IL00532192S9
M1D006007306
MID00293122B
MAD001041987
IUXJ21440375
MIU006030373
TX0980625453
100048340921
IDD04B340921
ILD01Q236230
NV09BOB13646
COO3807 17557
KSD980741862
WA0960726301
WAD980726301
IND0007 15490
NE221 3820234
PA0981 740061
TX0990707010
NYD091 972554
NY457 1924451
WA3890090076
WM890090075
WA1890090078
WA2890090077
OH00003//S11
ALD041906173
IL0980794333
NJD980505416
Study Type
yMtttnongy
Hegismes
Biological indicators ot
Ewosure
Epidemoiogy
Biological Indicatoraol
Exposure
Registries
Epidemiology
biological Indicators of
Exoosure
Epidemoiogy Study
Survedance
Registries
telogKal Indicators of
^IQOSUfB
eotagKalindNaiorsof
Exposure
Bolooica) Indicators of
exposure
Biological Indcaiors of
Exposure
Biological Indicators of
Exposure
Registries
Disease and Symptom
^evatence
Royistnes
Biological Indicators of
Exposure
Biological Indicators ot
Exposure
Disease and Symptom
Prevalence
Disease and Symptom
Prevalence
Disease and Symptom
Prevalence
Disease ana Symptom
Prevalence
Disease and Symptom
Prevalence
Bntoocal Indicators of
Exposure
Bnlogcal trefccalors of
Exposure
BoogKal uxxcalorsof
Exposure
Tracking System
Study Titto
Env Expo ana tneir Effects on tne
mmune System. NC
Trchtoroemytene
Allied Paper/Portage
Cteek/Katamazoo River. Ml
Analytic Epidemoiogtt Study ot
MBOCA.MI
Baud A McGinre Supertund Site,
MA
rncnofOBtnywno
Analytic Epidonvotogcc Study ot
MBOCA.M1
BnoRehmngCoyDuoeOil
^fQM>%|uys. TX
Case Control Study Blood Lead
Levels Silver Val.lD
Lead Screen Study/Silver Valley
(Bunker HtH> 10
rnctnorD6tttyi6fl6
Canon River Supertund Site. NV
Clear Ok/Central City Mine
Warn Exp Study. CO
Kansas Mutt-Site Lead fcxposure
Study. Galena. KS
Commencement Bay Exposure
Study. TacomaWA
PuyaUup Tribe Data Assessment
ofMoflatty.WA
TiBhforoetliylane
Comhusker Army Ammunition
Ptant Hal County, NB
rncnoiueiJiyiene
Crystal Cherncal Co. Arsenic
Expo. Study, TX
SL Raga. PCB From Toxic Waste.
NY
Grftss to Rxce Base. Home. NY
Hanford. WA
Hantord.WA
HantontWA
HantonLWA
UnMkiwn Vos Blood Testing
NearUndM.OH
Leeds. Child Lead Exposure
Study. AL
list* BeetrealUtaiies.il
Voluntary Residtm Trackng
Database. New Jersev
Started
9/16/93
B/t/88
9/30V93
9/25/91
8/1/88
9/25/91
12/1/91
11/1/92
9/30/89
8/1/88
9/30(89
7/1/90
9/1/84
6/1/89
8/V88
8/5/93
8/1/88
6/1/B8
9/30/89
7716/93
itVlfl/
9/15/88
9/30*3
9/1/90
Completed
,
3731/87
12/19/91
9/1/90
6/30A8
9/1/91
L
* Study protocol has been approved; data collection has not started.
"Public Health Assessment under development.
Information based on records in ATSDR's HazDat database, November 1993.
Date: 1/26/94
Question #11
-------
Exhibit 11-2 (continued)
Health Studies Initiated by ATSDR
Site Name
Uaywood Chemical Co.
McCWIanAFB
HcGnv-Edaon Company
HcKkiCO.
Umkar/SlouV Romano CiMk Site
New Bedford SM
Neweoni Brothers OM Refchotd sue
NL Mustriee/TARACORP ued SMELT
STIE
Oronogo-Ouenweg Mining Belt
OTIS Air National Guard/Camp
Ednrdt
PttMriMt Zinc Pile
Qua* Run Mobile Park
Quag Run MotMo Park
Rocky HowUi AiMnal
Rotfcy Mountain Araanal
iw-ruiiflco.
RSRCorp"
SE Rocktord Croundwaler Coot
StaAindoah statue*
ahwBovcnak
Slw Bow Creak
SauogMHounwn
England
TlnaaBaadt
TrMnvrnMTUi^nu
TueconMAftputAiu
(MM Cieueoflny Co.
V^MtWtfHM
V.uuwainaU
VcHf AC, Inc.
VaeW Water supply 1-1
WHIHrEbiMtBnU
CERCUS No.
NJ 0980529762
CA4570024337
MIDOOS339676
MED980524078
MOO980741912
MA0980731335
MS09aOB4004S
ILD096731468
M009806B62B1
MA2570024487
PAD002395887
M0098068B634
M009B0688634
C05210020769
CO52 10020769
Ml 0005340068
TXD079348397
ILD981000417
MO0980685838
U1MMSK777
MTU9903U27^
COO960806Z77
UIOOO9/W604
MO098068&226
IDD964666024
AZD980737530
TXD960745b74
Ml 0980 793806
MI0960793606
AHUUUUU0440
NVNU7H7K7
ILD006t14151
Study Typa
Hearai Stareacs Review
Disease ana Symctom
Pimaienca
Regstnes
Biotogcailnacatortol
Enxnura
Ragotnes
Epdamougy
Buk>9cai macaioa ot
Eqxaura
PiTT*f?yi^ Indcatofs 01
Exposun
Bolo^cai macalora ot
Ejposure
Disease aoo Symptom
Prevaianca
Boioqeailnaeaionol
Eoxnure
He^.-ies
EpdanvoioQy
Hrtoyjl Indmonol
Exposure
BriflyiJi •wfcfaiinAoi
Eoosum
EptJaiTMlogy
nrtnyat Inrtr mi of
Enonn
Rogatnn
RagBBies
IMAX^CM bvtcaloiiof
Eiqxmn
Rriflyji Ind^abm ol
E^xmn
Batooxa macaioft ol
EnxHure
Hrtoycal fcidcafiMiof
Eipoaura
na^stnas
Ortofpcjl IndcttDfSOl
Enposwi
Oocaaa and Symptom
Pmaianoi
Saa-Spacfc
SuvManca
Epdarnaogy
RatpUimt
Bdooxai induiiMS ot
Eipoawa
Ravaoiaa
HaoBtnaa
Study TWa
Maywooo Area Cancer
tnvanlH'MSon. New Jenav
McCMttn to Force Base.
Saotmemo. CA
TncManetnyiena
McKn Dunp Site Heam Eflecs
StuoV.Gny.ME
Ooan
Graalar New Bedford. MA, PCS
Health Effects Study
Newton Brothers NPL Site.
Cohmtn.MS
Unoit MulhSila LaaO closure
Study.!
MaaounMuft sue lead fcxpomB
Stud*Jopan.MO
OTIS Air Force Base. (-aJmoum.
MA
Paknanon Lead and Cadmun
Study. Pakneron. PA
Doai
linoun Pmon AOpoie rmue
Study
HMAPMExpsmdyParcLCO
HMA ReproMeuobanav
Dterden) n Communbe*. CO
Anajyic cpBiafliukjy saidyot
MBOCA.W
CMkfBod Blood Lead TeMng. TX
TncntoroaPiyiana
Omon
Simr Bow Creek Suparknd Site.
flockar.MT
Slw Bow CnMk. Blood Lead
Sixty. Wahentfe MT
SMUGGLER UouMan Site,
Aspen. CO Or CnMk Pan 1
SoUntt Hacovary Semen ol
NewEnganlCT
Dxmn
Tnumph Paiker Mne Dump S«e
IDAHO
Tucaon mamttonal Airporl SM.
AZ
Unnad Creoaoono, Company NA,
TX
Bade creak HeaM Hlaca
Stuov.u
Tncnlofoathytana
vem w; cxpoaura Study.
Jackacfw«a.AR
Benzene
Tnchtaroatfiylem
Started
916/93
815133
8/1/88
9/1/87
8/31/87
8/8/84
7/1/88
9/29/90
9/29/90
4/16/93
3/12/91
8/31/87
5/1/85
9/1/89
9/3W1
9/25/91
4/VS3
s/tna
B/3UB7
8/1/89
8/25/87
3/1/87
8/31/87
9/16/93
9/30/92
2/1/85
8/UB8
5/1/91
6/2/89
8/UB8
Completed
6/1/87
10/1/89
8/1/87
9/30/93
1/1/82
3/1/88
9/15/92
* Study protocol has been approved; data collection has not started.
"Public Health Assessment under development.
Information based on records in ATSDR's HazDat database, November 1993.
Question *n
Date: 1/26/94
-------
uestion#12
Site Operations:
The majority (69%) of all non-Federal Facility sites report a single past use, while the remaining sites
(31%) report multiple uses. Of the 750 single-use sites, the most common category of activities was
waste management (362 sites), followed by industrial (230 sites) and miscellaneous (158 sites). Of the
333 multiple-use sites, past industrial activities were cited most often (at 242 sites), followed by
miscellaneous (at 223 sites) and waste management activities (at 160 sites).
Of all 1,083 non-Federal Facility sites reporting, the most common waste management activity involved
the operation of landfills (267 sites).
For non-federal sites only, please identify what kind of
operation/activity was present at the facility, from the list of
possible operations/activities provided. Only one category
should apply to each facility.
Of the 1,083 non-Federal Facility sites providing informa-
tion on past activities, 750 sites (69%) had a single past use
and 333 sites (31%) had multiple uses. Of the 750 sites
reporting a single past use, the most common category of
activities was waste management (362 sites), followed by
industrial (230 sites) and miscellaneous (158 sites).
Almost one-half of the sites in the single-use category
reported past waste management activities. The primary
waste management activity at National Priorities List
(NPL) sites involved the operation of landfills. The most
common past industrial activity associated with single-
use sites involved the production of "Chemicals and
Allied Products (Standard Industrial Classification (SIC)
code 28)" (71 sites). (See Exhibit 12-1for other types of
operations at single-use industrial sires).
Of the 333 sites with multiple uses, some sites had multiple
activities overtime (e.g., the facility changed operations),
while at other sites there were two or more concurrent uses.
Thus the total number of uses exceeds the number of sites.
The most common category of past activities was industrial
(at 242 sites), followed by miscellaneous (at 223 sites) and
waste management (at 160 sites). (No corresponding
exhibit).
Background Information
About Site Activities
At many Superfund sites a variety of production and
waste management activities caused contamination.
For example, an industrial site might have had
several past production processes, as well as several
practices for managing the waste generated by these
processes. As a result, most of the non-Federal
Facility sites fall into the 'Other1 category as defined
by the Congressional inquiry. In order to more
accurately categorize sites, EPA requested that site
managers provide a listing of all Standard Industrial
Classification (SIC) Codes that characterize the full
range of past site activities.
What Is a Standard Industrial Classification
(SIC) Code?
The SIC was developed to classify establish-
ments by the type of activity in which they are
engaged. The SIC is intended to cover the entire
field of economic activities. Major groups of
economic activities are designated as two-digit
codes and used here in the analysis of past
operations at Superfund sites.
Question #72
Date: 2/4/94
-------
Exhibit 12-1
Types of Operations for Single-Use, Industrial, Non-Federal Facility Sites
INDUSTRIAL
(230 sites)
SIC 28 Chemicals and Allied Products
(71 Sites)
SIC 34 Fabricated Metal Products - except
machinery and transportation
equipment (45 Sites)
SIC 36 Electronic and Other Electrical
Equipment and Components -
except computer equipment
(37 Sites)
SIC 33 Primary Metals Industries (28 Sites)
Other Industrial (49 Sites)
Data Source
1) The source: August 1993 RPM Data Collection
(questions E4b and E5), CERCLIS database and
Woodtreat database.
2) The full universe of sites addressed by the question:
Those 1.126 final and deleted non-Federal Facility
sites listed on the NPL as of Julv 1993.
3) The subset of the universe for which data are pro-
vided: The 1,083 out of 1,126 non-Federal Facility
sites providing information on past site uses/types.
Date: 2 4/94
Question #12
-------
Question #13
Number of Parties at National Priorities List (NPL) Sites:
Three-quarters (75°0) of the non-Federal Facility sites have between 1 and 50 parties associated with
them. Fifty-nine percent (59%) of sites have 10 or less parties associated with them.
Please identify whether the best estimate of the total
number of PRPs associated with the facility that could
potentially be held liable under section 107 (irrespective of
whether EPA decides to pursue all of them) is (1), (2-10),
(11-50), (51-100), (101-300), (301-1,000), (1,000+).
Three-quarters (75^) of the non-Federal Facility sites i !•>>>
out of 1.126) have between 1 and 50 panics associated \v ith
them. The mode and median range of parties associated
with these sites is between 2 to 10 parties. (A distribution
of sites by range of panics associated with the sire i\
provided in Exhibit 13-1).
Exhibit 13-1
Number of Parties Associated with Non-Federal Facility Sites
450 -I
400-
350-
300-
1 250-
200-
150-
100-
50-
40%
17%
2%
17%
;196
9%
.5% .
6%
2%
~24~
2%
17
0%
1
None
2-10 11-50 £1-100 101-500 501-1000 >1000 Unknown No(Provid«d
Number of Parties Associated with a Site
Three-quarters (75%) of the non-Federal Facility sites reporting (839 out of 1,126 sites) have between 1 and
50 parties associated with them. The mode and median range of parties associated with a site is between 2
to 10 parties.
NOTE: Responses in the 'None' and 'Unknown' categories may include sites where baseline PRP search
activities have not been completed.
• This question only addresses 1,126 out of the 1,249 NPL sites because 123 sites are Federal Facilities.
Question #13
Date: 1/2&94
-------
Background Information
What is a "party associated with a site"?
A party associated with a site is one that EPA
initially identifies as being potentially liable
under CERCLA, and may include owners or
operators of the site, generators of the waste, or
transporters who disposed of material at the
site.
What is a mode?
The mode is defined as the observation which
occurs most frequently in a group of observa-
tions.
What is a median?
A median has a two-part definition: 1) the
median is defined as the middle observation of
an odd-numbered group of observations that are
ordered from smallest to largest; or 2) the
median is defined as the number halfway
between the two middle observations of an
even-numbered group of observations that are
ordered from smallest to largest.
Data Source
1) The source: August 1993 RPM Data Collection
(question El 3).
2) The full universe of sites addressed by the ques-
tion: The 1,126 final and deleted non-Federal
Facility sites listed on the NPL as of July 1993.
3) The subset of the universe for which data are
provided: Exhibit 13-1: The 1,125 out of 1,126
final and deleted non-Federal Facility sites listed
on the NPL that reported parties associated with
the site.
Date: 1/2&94
Questionf 13
-------
uestion#14
Types of Parties Associated with Sites:
About one-fifth (17%) of the non-Federal Facility sites have only a single party associated with the site.
Of these 195 single party sites. 164 (84%) are owner/operator sites.
For each facility where there is only one Potentially
Responsible Party (PRP), please indicate whether that
PRP is an owner/operator.
Of the 1.126 non-Federal Facility sites listed on the NPL.
1 T7c (195 sites) are single-party sites. Of these 195 single-
party sites. 164 (84%) are owner/operator sites. <.SVt-
Exhibition.
Exhibit 14-1
Single-Party Owner/Operator Sites*
84°'o
Single Party
17%
Multiple Parties
75%
Off-Site
Generator/Transporter
12%
'A or N/P'
85 Sites
Unknown Party Type
8 Sites
(4%)
Of the 1,126 non-Federal Facility sites on the NPL. 195 sites have only 1 (a single) identified party. Of these
195 single-party sites, 164 (84%) are owner/operators (i.e., no off-site generation of waste). In addition,
some of the 846 multiple-party sites may also be owner/operator-on/y sites.
* This question only addresses 1.126 out of. the 1,249 NPL sites because 123 sites are Federal Facilities.
" NOTE: N/A or N/P represents sites where information was either not applicable or not provided.
Question #14
Date: r/
-------
Background Information
What is an owner/operator - only site?
Sites with only owner/operator parties are defined
as those sites where no hazardous substances
were contributed by any off-site generator/trans-
porters. The universe of single-party, owner/
operator sites reported includes those parties who
could potentially be held liable under CERCLA,
irrespective of whether EPA decides to pursue
them.
DataSource
1) The source: August 1993 RPM Data Collection
(questions E13, E14, E26 and E28).
2) The full universe of sites addressed by the ques-
tion: The 1,126 final and deleted non-Federal
Facility sites listed on the NPL as of July 1993.
3) The subset of the universe for which data are
provided: The 1,041 non-Federal Facility sites
that reported at least 1 PRP.
Date: 1/26/94
Question H4
-------
Question #15
Owner/Operator Parties:
Forty-one percent (41%) of non-Federal Facility sites have only owner/operators as PRPs.
Please indicate where the only potentially responsible
parties are owner/operators (i.e., no hazardous sub-
stances were contributed to the facility by off-site
generator/transporters).
Of the 1,075 (out of 1,126) non-Federal Facility sites that
indicated the types of parties associated with the sites,
41% (457 sites) have only owner/operators associated
with them (i.e.. no off-site wastes were contributed to the
site). (See Exhibit 15-1).
Dat^ource
1) The source: August 1993 RPM Data Collection
(question E14).
2) The full universe of sites addressed by the ques-
tion: The 1,126 final and deleted non-Federal
Facility sites as of July 1993.
3) The subset of the universe for which data are
provided: The 1.075 (out of 1.126) non-Federal
Facility sites reporting, which include those
panics who could potentially be held liable under
CERCLA. irrespective of whether EPA decides to
pursue them.
Exhibit 15-1
Breakout of Parties Associated with Non-Federal Facility Sites
50%
Unknown
Party Types
41 Sites
(4%)
Owner/
Operators
as Only
Parties
457 Sites
Owner/
Operators
and/or
Other
Types of
Parties
568 Sites
N/AorN/P
60 Sites
(5%)
41%
* This question only addresses 1 ,126 out of the 1,249 NPL.sites because 123 sites are Federal Facilities.
** NOTE: N/A and N/P represents sites where information was either not applicable or not provided.
Question #15
Date: 1/2&94
-------
Question #16
De Minimis Parties:
There are 220 sites where sufficient volumetric data exist to establish whether there are parties
associated with the site who contributed "minimal" amounts of hazardous substances to facilities and
could Reconsidered de minimis. The new de minimis guidance, issued in July 1993. establishes that
the Agency must simply find that the individual de minimis party's contribution is minimal in comparison
to the total waste at the site. At the sites where sufficient data existto determine volumetric contribution.
almost two-thirds have been identified as having at least one potentially de minimis party; however de
minimis settlements may have already been reached. In addition, at 33 sites where sufficient data is
available, data indicate that no de minimis parties are likely to exist.
Please indicate whether sufficient volumetric data exist to
establish whether there are PRPs who contributed small
amounts of hazardous substances to facilities and could
be considered de minimis parties.
There are 220 sites where sufficient volumetric data exist
to establish whetherthere are PRPs who contributed "mini-
mal" amounts of hazardous substances to facilities and
could be considered de minimis. I See Exhibit 16-11.
Exhibit 16-1
Distribution of Sites with Potential De Minimis Parties *
23%
43%
53%
SituWlwt
PoMnUalOt
UimmaSaUu
Awifcng Vohmwatc
AnilyiK
24%
There are 220 sites where sufficient volumetric data exist to establish whether there are PRPs who contributed
"minimal" amounts of hazardous substances to facilities and could be considered de minimis. EPA regional officials
have indicated that there may be de minimis parties at 160 of these sites. Of the 60 remaining sites, once the volumet-
ric data is analyzed, some may be found to have no de minimis parties.
• This question only addresses 1.126 out of the 1,249 NPL sites because 123 sites are Federal Facilities.
•• NOTE: N/A and N/P represent sites where information was either not applicable or not provided.
Question #16
Date: 1/26/94
-------
Background Information
How does a party qualify as de minimis?
De minimis waste contributors are generators or
transporters whose waste contribution is
minimal - in both volume and toxicrty - com-
pared to the other hazardous substances at the
site. Frequently these parties have contributed
less than one percent of the waste at the site.
However, whether individuals qualify for a de
minimis settlement depends on a variety of site-
specific factors. For example, the cut-off
established for de minimis eligibility often varies
from site to site.
What is a waste-in list?
A volumetric ranking, or "waste-in list," is an
inventory of all the off-site waste generators
involved at a site and the waste contribution of
each. Organized in descending order of contri-
bution volume, this ranking facilitates a de
minimis determination. Although an extensive
waste-in list frequently identifies some number
of de minimis parties, some sites where a
waste-in list has been (or could be) prepared
may not involve any de minimis parties.
What does the "Streamlined Approach for
Settlements with De Minimis Waste Con-
tributors" say?
This new guidance, issued on July 30,1993,
establishes the minimum level of information
required before EPA can make a de minimis
finding. The guidance states that it is no longer
necessary to prepare a waste-in list or volumet-
ric ranking before considering a party's eligibility
for a de minimis settlement. However, EPA still
must demonstrate that the potential de minimis
party's waste contribution is minor, in both
volume and toxicity, and that the settlement is in
the public interest and involves only a minor
portion of the response costs at the site.
For each such facility, please indicate the number of
potential de minimis parties.
Although EPA has sufficient information to assess whether
de minimis parties may exist at each of these 220 sites, this
analysis has not been conducted at all of these sites. At 1 60
sites, however, EPA regional officials have indicated that
there may be de minimis parties. While the precise number
of potentially de minimis parties at each of these 1 60 sites
is not known, the median range of potential de minimis
parties at each site is between 1 1 and 50 parties. (No
corresponding exhibit).
Of the remaining 60 sites, once the volumetric information
is analyzed, some may be found to have no de minimis
parties. Thus, EPA cannot currently estimate "the number
of potential d^mtrumtJ parties" at each of the 220 sites. (No
corresponding exhibit).
For each such facility, please identify where a wasted list
has been or could be prepared based on the data available
to EPA.
Of the 220 sites where sufficient volumetric data exist to
establish whether there are PRPs who contributed "mini-
mal'' amounts of hazardous waste, a waste-in list has been
prepared, or could be prepared, at 145 sites. (No corre-
sponding exhibit).
NOTE: According to the recently issued "Streamlined
Approach with De Minimis Waste Contributors," the prepa-
ration of a waste-in list is not required prior to finding a
party eligible for de minimis settlement.
1) The source: August 1993 RPM Data Collection
(questions E17, E18a, E19, E20a and E20b).
2) The full universe of sites addressed by the ques-
tion: The 1,126 final and deleted non-Federal
Facility sites listed on the NPL as of July 1993.
3) The subset of the universe for which data are
provided: Those 220 sites where PRPs could be
considered de minimis parties.
Date: 1/26/94
Question t16
-------
uestion#17
Financial Viability and Waste Contribution:
Over one-third of NPL sites (398) have at least one non-viable responsible party. Non-viable parties
are more likely to be owner/operators (81 % of sites), than generator/transporters (52% of sites). Non-
viable generator/transporters, on average, contributed 42.5% of the waste volume at sites with
sufficient waste volume information available.
Please indicate where there are orphan parties (i.e., parties
that are not financially viable or cannot be located).
Of the I.I05 non-Federal Facility sites reporting, 398
(36%) have at least 1 non-viable responsible party.
NOTE: Twenty-one (21) of the 1.126 non-Federal Facility
sites did not respond to this question. Two hundred and
twenty-five (225) sites reported the parties as 'Unknown.'
indicating that the financial viability of all PRPs at these
sites has not been determined. At a majority of these sites.
all PRP search activities have not been completed. There-
fore, some or all of the 225 sites reporting "Unknown" may
have non-viable responsible parties.
For each of those same facilities, indicate whether all the
owner/operators are orphan parties.
Of the 398 sites with non-viable responsible parties
reporting, 321(81%) have one or more (but not necessar-
ily all) owner/operators as non-viable parties. One-
hundred and thirty-two (132 or 41%)of the sites with
non-viable owner/operators also had one or more (but
not necessarily all) non-viable generator/transporters.
(See Exhibit 17-1).
Where sufficient volumetric data exist, please provide the
best estimate of the percentage, by volume, of waste
contributed to the site by generator/transporter orphan
parties.
Of the 211 sites reporting the presence of non-viable parties
that are generator/transporters, 87 sites (41%) had suffi-
cient volumetric data to report the average volume of waste
contributed to sites by these non-viable generator/trans-
porters. The average volume contributed to sites by these
parties is 42.5%.
Exhibit 17-1
Sites with Non-Viable
Responsible Parties
Total number of sites reporting where there is at
least one non-viable responsible party = 398
Onlytewitori
Tfvupoftcn
77 Sues
(19%)
Total Sites with One or More
Generator/Transporters
Total Sites with One or More 209 Sites
Owner/Operators (52%)
321 Sites
(81%)
NOTE: Twenty-one (21) of the!, 126 non-Federal Facility
sites did not respond to this question. Two hundred and
twenty-five (225) reported the financial viability of parties as
'Unknown.' indicating that the financial viability of all PRPs at
these sites has not been determined. At a majority of these
sites, all PRP search activities have not been completed.
Therefore, some or all of the 225 sites reporting 'Unknown'
may have non-viable responsible parties.
NOTE: Questions 17, 18 and 19 must be read in
tandem to obtain a more complete picture of the
potential Fund exposure.
Question #17
Date: 1/26/94
-------
Background Information
What is a non-viable responsible party?
For the purpose of this analysis, a non-viable
responsible party was defined as a party
associated with a site who the Agency cannot
locate or believes is not financially viable.
Data Source
1) The source: August 1993 RPM Data Collection
(questions E21, E22, E23 and E24).
2) The full universe of sites addressed by the ques-
tion: The 1,126 final and deleted non-Federal
Facility sites on the NPL as of July 1993.
3) The subset of the universe for which data are
provided: Those 398 non-Federal Facility sites
reporting non-viable responsible parties, exclud-
ing those 225 sites reporting financial viability as
'Unknown'.
Date: 1/26/94
Question #17
-------
Question #18
Sites with A/on- Viable Parties:
There are currently 93 sites on the NPL with no enforcement potential. The government does not
expect to obtain work or recover costs from PRPs at these sites.
Please indicate whether the government believes that
there are no financially viable parties, or no parties that
can be found, and that the Trust Fund will have to pick
up 100% of site study and cleanup costs.
At less than 10% (93 sites) of the 1,126 non-Federal
Facility sites, all parties are not financially viable or
cannot be. located. (See Exhibit 18-1).
NOTE: 'Unknown' responses may include sites where
baseline PRP search activities have not been completed.
NOTE: Questions 17,18 and 19 must be read
in tandem to obtain a more complete picture of
the potential Fund exposure.
Exhibit 18-1
Enforcement at NPL Sites
Total Sites Reporting
Excluding Federal Facilities =1,126
No Enforcement Potential
93 Sites
(8.3%)
Unknown Enforcement
Potential
18 Sites
(1.6%)
Partial PRP
Response/Cost
Recovery Posaible
353 Sites
Full PRP
Response/Cost
Recovery Possible
662 Sites
31.3%
58.8%
At 93 sites (8.3%) of the 1,126 final and deleted non-Federal Facility sites, all parties are not financially viable or cannot be
located and have no enforcement potential.
This question only addresses 1,126 out of the 1,249 NPL sites because 123 sites are Federal Facilities.
NOTE: 'Unknown' responses may include sites where baseline PRP search activities have not been completed.
Data Source
1) The source: August 1993 RPM Data Collection
(question E26).
2) The full universe of sites addressed by the ques-
tion: The 1,126 final and deleted non-Federal
Facility sites on the NPL as of July 1993.
3) The subset of the universe for which data are
provided: The 1,126 non-Federal Facility sites
listed final and deleted on the NPL.
Date: 1/26/94
-------
Question #19
Fund-lead Sites:
PRPs are increasingly taking responsibility for the RA
(construction phase) of site cleanup, which is the costli-
est phase of cleanup. (See Exhibit 19-2). Data from
CERCLIS (Superfund's official information system)
suggest PRP involvement at 70% of remedial design
starts and 77% of remedial action starts at NPL sites
during FY 92 and FY 93.
About one-quarter of sites (317) are Fund-lead. Of these, 90% will continue to have Fund-lead events,
while only 7% of the non-Federal Facility sites are expectej to have Fund-financed work for the first
time in the future.
Please indicate whether the facility is Fund-lead or
expected to be Fund-lead.
Site activities are often led by one or several panics over
the course of the entire site cleanup process. This
analysis focuses on the lead for key cleanup activities at
sites(i.e..RI/FS.RDandRA). (See key to Exhibit 19-1).
While some sites are currently Fund-lead and others may
have future Fund-financed work, their status is subject to
change as response actions progress. Therefore, any
given site can have events financed both by PRPs and the
Fund. Since EPA assigns leads only to individual events
such as site studies, design and construction, a Fund-lead
site simply means that all these site events have been, or
are now being paid for, by the Fund.
Of the 1,126 non-Federal Facility sites, 317 sites (28%)
are currently Fund-lead, 732 sites (65%) are PRP-lead
and States have financed cleanups at 36 sites (3%). At
the 41 remaining sites (4%) no response events have
been started. (See Exhibit 19-1).
Site managers reported that of the 317 current Fund-lead
sites, 308 will continue to be Fund-lead. The PRPs are
expected to be doing all future work at 646 sites, 78 sites
are expected to have Fund-financed work for the first
time in the future and the future lead status is undeter-
mined at 94 sites. (See key to Exhibit 19-1).
1) The source: August 1993 RPM Data Collection
(question E27) and CERCLIS database.
2) The full universe of sites addressed by the ques-
tion: The 1,249 final and deleted NPL sites as of
July 1993 (123 Federal Facilities and 1,126 non-
Federal Facility sites).
3) The subsets of the universe for which iaia are
provided: The 1,126 non-Federal Facility sites.
NOTE: Questions 17,18 and 19 must be read in
tandem to obtain a more complete picture of the
potential Fund exposure.
Question #19
Date: 1/26/94
-------
State-financed
36 Sites
Exhibit 19-1
Current Superfund Site Leads*
Uninitiated
41 Sites
(4%)
28%
65%
Lead
PRP
Fund
State-
financed
Uninitiated
Some or all site study (RI/FS), design (RD) and
construction (RA) events have been or are
being paid for by PRPs. Some Fund or State
dollars are spent to provide oversight for PRP
cleanup activities. __
RI/FS, RD and RA events at the site have been
or are now being paid for by the Fund. Some
State dollars also may have been spent
All RI/FS, RD and RA events have been or are
being paid for by the State (no Fund dollars are
involved).
Either no response events have been planned,
or none will occur.
Of the 1,126 non-Federal Facility sites, 317 sites (28%) are currently Fund-lead, 732 sites (65%) are PRP-
lead and States have financed cleanups at 36 sites (3%). At the 41 remaining sites, no response events
have been planned.
* This graphic only addresses 1,126 out of the1,249 sites because 123 sites are Federal Facilities.
Date: 1/2&94
Question f 19
-------
Exhibit 19-2
Construction Start (RAs) Lead Trends
Fund vs. PRP
PRP-leadRAs
Fund-lead RAs
1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993
Fiscal Year of RA Start
Data show that PRPs are increasingly taking responsibility for the RA (construction phase) of site cleanup,
which is the costliest phase of cleanup.
Question *19
Date: 1/26/94
-------
uestion #20
Cost Recovery:
EPA can potentially recover almost $4 billion in past costs at more than 3,000 National Priorities List (NPL) and
non-NPL sites. EPA has already taken some action to recover past costs of $2.17 billion at more than 2,000
of these sites (67%). Slightly more than $1 billion has been recovered, leaving an additional $1 billion currently
being sought
Please indicate where EPA has expended funds that are
recoverable under Section 107 and the amount of those
recoverable expenditures.
Omitting orphan sites (sites where EPA has not identified
a financially viable PRP) and Federal Facilities, there are
approximately 3,185 sites (NPL and non-NPL) at which
EPA has incurred costs that are recoverable underCERCLA
Section 107. Potentially recoverable past costs at these
sites is just under $4.0 billion.
Indicate whether a cost recovery action has been filed to
recover those funds, whether funds have been recovered
and the amount that has been recovered.
EPA has taken cost recovery action to address $2.17 billion
in past site costs at 2,140 sites^67% of the non-orphan, non-
Federal Facility sites). Of this amount, $1.11 billion has
been recovered through settlements with PRPs; the balance
is still being sought.
Cost recovery actions to date include 639 cases which were
referred to the Department of Justice for legal action. A
total of $1.35 billion has been achieved or is still being
sought through these cases.
Indicate whether or not the statute of limitations (SOL) is
expected to be a bar to cost recovery of any amount
There are 103 non-Federal Facility sites at which the initial
SOL will expire in fiscal year 1 994 (FY 94). EPA hopes to
address all of the FY 94 SOL cases, either by initiating a
cost recovery action or by documenting the reasons why
cost recovery action will not be taken prior to the expiration
oftheirSOLs. EPA has planned a total of 1 19 cost recovery
actions in FY 94.
1) The source: Financial data from SCORES, includ-
ing both direct and indirect costs for each site,
CERCLIS data as of 10/22/93, U.S. Treasury
Collections Data as of 9/30/93 and Cost Recovery
Branch FY 94 Targeting Report.
2) The full universe of sites addressed by the question:
The 1,126 final and deleted non-Federal Facility
sites on the NPL and 2,161 non-Federal Facility
sites not on die NPL for which cost data is readily
available.
3) Subset of the universe for which data are provided:
Revised universe of NPL sites is 1,024 after sub-
tracting 93 orphan sites; data are provided for all
2,161 non-NPL sites.
Question #20
Date: 1/26/94
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Question #21
Projected National Priorities List (NPL) Additions:
Based on a poll of the Regions. EPA estimates That oetween 75 and 95 sites will be added to the NPL in
FY 94, and an additional 340 to 370 sites will be added between October 1,1994 and October 1,1999. In 1994.
EPA expects that the majority of new sites wiii De industrial facilities (61%) and waste management facilities
(26%). Additions to the NPL between the beginning of FY 95 and the end of FY 99 are expected to be nearly
70% industrial and 15% waste management. Actual NPL listings will depend on resource commitments.
reauthonzation mandates and policy decisions.
Please obtain from Regional officials in each Region
their best informed judgement with respect to the
number of facilities in their Region that will be added to
the NPL in the period from October 1,1993 to October 1,
1994 and in the five year period from October 1,1994
and October 1,1999. To the extent possible, please
obtain information concerning the types of facilities that
will be added to the NPL during the periods referenced
above.
The projected additions to the NPL from October 1.1993
through September 30, 1994 is between 75 and 95 sites.
Of these sites, 68% are expected to be non-Federal
Facility sites and 32% are expected to be Federal Facili-
ties. The estimated breakdown of the non-Federal Facil-
ity sites by type is: 62% industrial, 2t 7c waste manage-
ment and 12% miscellaneous. The industrial category
consists of metal fabrication, electrical manufacturing
and equipment, lumber/wood treaters. dry cleaners and
chemical manufacturing. (See Exhibits 21-1 and 21-2).
The projected additions to the NPL from October 1.1994
through September 30, 1999 is between 340 and 370
sites. Of these sites, 80% are expected to be non-Federal
, Facility sites and 20% are expected to be Federal Facili-
ties. The estimated breakdown of the non-Federal Facil-
ity sites by site type is: 68% industrial, 15% waste
management and 17% miscellaneous. {See Exhibits
21-3 and 21-4).
These projections are based on a range of factors related
to site assessments:
• Staffing and site-specific budget allocations:
• Impact of the implementation of the Superfund
Accelerated Cleanup Model, reauthorization and
other program improvement initiatives:
• States' role in site assessments;
• The number of sites currently in the pipeline for
NPL proposal, a portion of which will not actually
be proposed because they do not meet the techni-
cal specifications for listing; and
• In some Regions, the priority needs of addressing
Federal Facilities in response to legal actions.
Please obtain the opinion of Regional officials with
respect to the number of facilities currently on
CERCLIS, other than those for which a determination
has been made not to list, which are ultimately likely to
be added to the NPL
All Regions found it difficult to estimate the number of
facilities currently in CERCLIS that are likely to be
added to the NPL. The Regions cited lack of active site
discovery programs and a backlog of completed site
inspections without listing decisions as factors that pro-
hibit making an accurate estimation.
EPA polled all Regional officials involved in site assess-
ment screening; however, accurate NPL listing forecasts
were difficult to make because cf the uncertainty of
future resources. NPL listing is always a resource-
constrained consideration.
Question #21
Date: 1/26/94
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Estimated Additions to the NPL by Site Type
Exhibit 21-1
FY94
Total Universe=75-95 Sites
Exhibit 21-3
FY95-FY99
Total Universe=340-370 Sites
Federal
NofrFMferal
FacflttyStes
68%
Exhibit 21-2
FY94
Non-Federal Facility Sites=51-65 Sites
Exhibit 21-4
FY95-FY99
Non-Federal Parity Sites=272-296 Sites
The MsceUaneous1 category includes those facflities that do not have erlherirxluslrial or waste management
operators on-site, and are often contaminated by off-site operations, activities or as a result of spis(e.g.,
residential areas, storage fadKies, wells).
NOTE: Ranges in pie charts were calculated based on the percent of each site type Regional officials
expect to be listed.
Date: 1/26/94
Question t21
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