u
    .
               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON, D.C. 20460


                             APR  T !S92


                                        PUBLICATION NO- 9203.1-01
                                                        OFFICE OF
                                               SOLID WASTE AND EMERGENCY RESPONSE
                       IMPORTANT - ALL READ


    BECAUSE THIS MEMORANDUM  18  SO  IMPORTANT,  I AM DIRECTING
       DESK-TO-DESK DELIVERY TO EVERY SUPERFUND EMPLOYEE
MEMORANDUM

SUBJECT:  Superfund Accelerated Cleanup Model (SACM)
FROM:     Don R. Clay  Te/r-^/'C
          Assistant Administrat^,

TO:       All Superfund  Staff, Managers,  Regions, and TTQs


     As most of you know,  the Office of Solid Waste and Emergency
Response, Office of Emergency and Remedial Response, has been
working on a new model for streamlining and accelerating the
Superfund program.  Plans  for full development of: the Superfund
Accelerated Cleanup Model  (SACM)  began after the Administrator's
approval on February 27.

     The concept, borne  of staff  creativity and Total Quality
Management, has been designed to  make Superfund work better, and
deliver results the public will value: 1)  quick reduction of
acute risks at all Superfund sites (removal and remedial) and 2)
restoration of the environment over the long term.  The new model
consists of:

     o    A one step site  screening and risk assessment at the
          front end of the process

     o    Regional management teams to "traffic cop" all sites
          to:

          1) Early Action  to reduce immediate risk to people and
             the environment and/or

          2) Long-term Cleanup to restore environment; and

     o    A combination  of enforcement, community relations and
          public involvement throughout the entire process.
                                                          Printed on Recycled Paper

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                                -2-
     The promise of implementing SACM is that we can achieve
immediate risk reduction at a larger number of sites, do the work
more efficiently,  move more money into actual cleanup, and work
more effectively by eliminating duplicative assessment steps.

     Representatives from Headquarters and the Regions will meet
in mid-April  to brainstorm, resolve issues, and develop solutions
and real-time plans to implement SACM.

     This concept has been presented to diverse and sizable
audiences,  and while it has produced many comments and questions,
it has been well-received and has generated a good deal of
enthusiasm and support.

     Since this will be the future of the program, I urge you
to familiarize yourself with the SACM conceptual write-up and
briefing package attached.  I also urge the development of dialog
on SACM implementation at all levels and across all functions in
the Superfund program, both in Headquarters and the Regions.
I will keep you informed of updates and changes that may occur.

Attachments

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                       SUPERFUND ACCELERATED
                       CLEANUP MODEL (SACM!)

                     THE NEW SUPERFUND PARADIGM

Introduction



   The present Superfund program operates within a complex and, at times circuitous

pattern that was designed ten years ago to accommodate a new and complicated law,

then tinkered with as the program lurched from its infancy.  The result has been a

somewhat "jerry built" structure, altered to fit everyone's perceived needs and a host of

conflicting expectations, but basically satisfying few. Early implementation focused on

numerous intricate administrative and legal requirements. However, recent budget

emphasis has dramatically shifted towards construction; policy emphasis has moved from

Fund to enforcement. Various committees and workgroups  continue to suggest ways to

speed up the  process.  Congress will soon consider many ideas for restructuring under

Reauthorization.



   Amidst this evolution, however, a few facts are unlikely to change - the public does

not understand our present process or grasp the full scope of pur work.  It wants faster

cleanups, and believes that enough money has been given to Superfund to get the job

done. The bottom line is that we can expect neither a lowering of expectations, nor a

rise in resources. These factors have crystallized into a new focus on radically speeding

up and streamlining the program.

                                                 OERR/OSWER  3/1/92

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                                      -2-




Background








   The current system for Superfund cleanups is based on two discrete programs -



remedial and removal. The remedial component is a series of steps to define and



address long term cleanup sites on the National Priorities List (NFL).  Separate and



apart are the activities of the removal program. These sites enter our system through a



different "door," usually the States (through the National Response Center) seeking our



help at a specific release. Some are spontaneous "screaming emergencies," others are



prioritized for short term action as money becomes available. While the removal



program generally does not address ground water, many of the other risks and response



actions associated with the two programs are similar. Yet, there are enormous



differences between remedial and removal actions regarding the depth of investigation,



and cost and time expended to complete a cleanup.








   In summary, the innate complexity of our process and our heretofore unsuccessful



attempts to portray progress have left the Superfund program highly vulnerable to



criticism.   Therefore, we must focus attention on a few major outcomes that the public



will value. -  We must make sure we deliver these outcomes and do it in terms the



public will understand.  For this reason, the new Superfund paradigm must be:








            o      simple and flexible -- to allow fastest



                    possible, worst first, risk reduction;

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                                      -3-
            o       free of administrative contrivances that

                    divide and diffuse the totality of reduced

                    risk at remedial and removal sites;

            o       realistically achievable in that we make

                    realistic cleanup commitments and deliver

                    them on time; and

            o       focused on rapid protection of people and the

                    environment and disconnected from the single

                    and unattainable goal of returning all

                    groundwater to pristine condition.


                                                       ;
The New Suoerfund Accelerated Cleanup Model




   Under this paradigm all sites on which Superfund takes any kind of cleanup action

are Superfund sites.  The distinctions between "remedial" and "removal" are eliminated.

Rather than viewing these two entities as separate programs, they are viewed as separate

legal authorities with different, but complimentary, application at Superfund sites.




   Rather than entering the program through one of two doors marked "remedial" or

"removal", all sites enter through one marked "Superfund".  All site assessment takes

place in one program, combining, as appropriate, elements of present removal

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assessments, PA/SIs, RI/FSs, and risk assessments.  During the assessment process, a



Regional Decision Team institutes short term activities that address all threats to the



health and safety of the existing population.  These actions include cleanup activities



generally taking no more than three or, at the most, five years - a reasonable time frame



based on the program's demonstrated ability to identify and address immediate risks to



people and  the environment within three to five years.                '








   These activities are published in the Federal Register (for public information



purposes only, not as a rulemaking) on an Early Action List. It is crucial to note here,



that though these actions 'are "short term" and quickly implemented, they could  eliminate



the majority of human risk from Superfund sites. Enforcement activities would



commence with immediate PRP notification, expedited orders/negotiation, and



opportunity for voluntary cleanup.  Because the vast majority of risk reduction occurs in



this part of the program, most of EPA's public participation/information activities are



focused here. Community relations and opportunities for Technical Assistance  Grants



(TAGs) continue as they do today. The State role is confirmed in its present



configuration;  further, they can continue with their own State-funded programs, resulting



in a net increase of cleaned-up sites nationwide.








   The Regional Decision Team can also determine if and when long term remediation



(e.g., ground water restoration) is appropriate. Sites would then be placed on the Long

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                                      -5-
Terra Remediation List (formerly known as the NPL), and cleaned up over many years.

Regional Decision Teams could also decide that no Federal action was appropriate or

that the site should be deferred to RCRA or other response authority.



   The major parameters of this concept are outlined below.



            1. Single Site Assessment Function. There are a number of redundancies

            in the beginning of the program as it is structured today.  Hazardous waste

            sites can receive numerous similar, but sequential, assessments before any

            kind of cleanup begins.  Sites are evaluated by the removal program

            (removal assessments), the site assessment program  (PAs, Sis, Expanded
                                                    ;
            Sis, and Hazard Ranking System (HRS) scoring), the remedial program

            (RIs, baseline risk assessments, and FSs), and even the RCRA program.

            ATSDR, State, local, and private party assessments may also occur. Many,

            if not most of these assessments start from scratch, - they do not

            necessarily take into consideration the  information and data generated by

            the studies that preceded them. This happens not only because of the

            obvious financial incentives to the contractor community and the human

            inclination to distrust the work of others, but because each part of the

            program is gathering data to respond to its particular perceived need. The

            site-assessment program wants to know if it will score on the HRS; the

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                        NEW   SUPERFUND  PARADIGM
                             Public Notification of Early Action Start
     PRP Search / Notification
 All
Sites
Start
    Site
 Screening
      &
Assessment
              No
            Action
                                       Early
                                      Action
                                 To Reduce Risk
                                    (< 5 Years)
                                      Issue Order/
                                       Negotiate
                                                                           Public Notification of Completion
                                                      Issue Order/
                                                       Negotiate
                                            Enforcement Activities
                                  State / Public Participation/Community Relations
                                                                        Early Action
                                                                         Completed
      Regional
Decision / Management
       Team
Long Term
 Hazard
 Ranking
                               RCRA
                                 or
                            Other Authority
    Long
   Term
   Action
     for
   Media
Restoration
 (> 5 Years)
                                                                  Long Term
                                                                   Cleanup
                                                                  Completed
                                                                                            [ Delete I

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removal program wants to know if the site is going to blow up; the



remedial program wants to know the extent of the ground water plume, the




size of the cap, etc.








   Large amounts of tune and money are expended on the process of



executing separate contracts, mobilizing sampling teams, designing




sampling strategies, modifying health and safety plans, etc., as each part




of the program goes out to "feel a different part of the elephant."



Assessment, in all of its forms, now absorbs far more  time than any other



part of the process.  The public believes that the program has been




cleaning up sites for ten years with little result.  It does not know  that



much of this time has been spent in  various parts of the assessment




process.  Whole steps in this redundant process must be combined if the



goal of expediting cleanup is to be achieved. The FIT/TAT contract




mechanism could support this combined assessment effort and thereby



assist in blending the remedial/removal "cultures."








   In some Regions, there will be no reason for a two-staged screening




function (PA followed by SI) since there will be no backlog of sites to be



screened.  Discovered sites could be screened once and, if serious, go

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                          -7-
directly to RI level data collection and risk assessment. Appropriate short



term cleanup activity, combined with public participation/outreach, and



expedited enforcement action (i.e., PRP search, information gathering, and



notification) could begin immediately. .These changes in the assessment



process could save several years, since the level and type of risk posed by



the site would be understood and often eliminated prior to listing.








    Placing all site assessment activities in one area would require the



development of new protocols but they would serve many needs.  Rigid



QA/QC procedures would assure the integrity and multiple-usability of the



data developed.








2.   Regional Decision/Management Teams. Regions often know the most



likely course of action to remediate a site well before the decision process



allows them to act.  In future years that  capacity certainly will expand. The



Region Decision Teams would "traffic cop" sites onto the Early Action List



and/or score long term restoration actions such as ground water sites for



inclusion on the Long Term Remediation List.  In addition, standards for



both remediation levels and technologies are likely to have been developed



and accepted. This move toward standardization will both speed up the



decision making process and allow increased flexibility in the staging or

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                                 -8-
      timing of various activities. The chief benefits are the ability to:




      o  make early action decisions while studies continue;




      o  cany out relatively short term cleanup steps that

         may in many cases be all that is necessary without    '

         triggering the site listing process;




      o  stay flexible while various activities are going

         on, rather than keeping functions in rigid and

         sequential boxes;
                                                  ;



      o  effectively utilize the decision making expertise

         in the Regions, delegating where appropriate

         (e.g.,  standard remedy selection), to the project

         manager level to speed cleanups; and




      o  realize time  and cost economies.




    Regional Decision/Management Teams would require the skills of the most

experienced managers (Fund and Enforcement),  site and risk assessors, on-scene

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                               -9-
coordinators (OSC), remedial project managers (RPM), Commumty Relations



coordinators and State officials, as appropriate. The OSC and RPM individual



site management function would eventually become combined, which would



further increase the efficiency of the process. Enforcement orders and




negotiations would be conducted within strict deadlines.  Cleanup could be



performed by PRPs and appropriately overseen by the Agency. Training and



commitment on the part of Superfund Headquarters and Regional management



can help overcome different cultures that now exist and use the combined



expertise in the remedial, removal, and  enforcement programs to achieve the



common goal of risk reduction.








3.  Early Actions. Risks at NPL sites fall into a number of categories, but most




commonly are  associated with the direct contact with wastes or contaminated soil,



or drinking contaminated water from ground water sources. Source control steps



taken early in the remedial process, such as drum removal, soil cleanup and



access restraints, as well as alternate drinking water provision, frequently provide




substantial risk reduction to existing populations.  Actions taken under removal



authorities are designed to address just  such risks.








    Early Actions would be an expansion of current removal activities. In fact,




we have already interpreted and expanded removal authority to allow continuing

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                                -10
cleanup actions at NPL sites if consistent with remedial actions (e.g., Radium

Chemical, White Chemical, Avtex, Publicker).  True emergency situations such as

train derailments would continue to be handled as they are today. Surface

cleanup associated with remedial actions, (i.e. actions other than long term ground

water pump and treat or extensive site restoration technologies such as large

mining site cleanups, wetlands/estuaries remediation, or extended incineration

projects), would be carried out through the Early Action phase of the program.

This would include such activities as:



             o  waste and soil removal,

             o  preventing access,
                                                 /
             o  capping landfills,

             o  moving people,

             o  providing alternate drinking water sources.



Most important, all immediate threats to public health and safety would be

addressed in this part of the process.  While  standardized cleanups for similar

sites would expedite many cleanups, innovative technology would be used

whenever it is faster, more efficient, more acceptable to the public, less expensive,

or less environmentally impactive.  Both standardized and innovative treatment

technologies offer opportunities for cost efficiencies.

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                               -11-
    The public could be notified of activities at these Superfund sites through a



quarterly Federal Register notice - the Early Action List.  Sites would be listed



when the decision to cleanup was made, then documented and delisted when the



work was completed. Public input would be achieved through all the mechanisms



(possibly including TAGs) that are now used by the program's community



relations professionals.  Most important, Superfund progress would be measured




against all of its risk reduction activities and most of those activities would be



completed rapidly.  Under the  New Superfund Accelerated Cleanup Model, the




Agency would commit itself first and foremost to substantially reducing or



eliminating threats to public health and the environment within a specified time




frame and that time frame would be short. This commitment would be EPA's



primary measure of success.








4. Long Term Remediation.  Sites requiring ground water restoration or long




term remediation (e.g., mining sites, extended incineration projects,



wetlands/estuaries)  would be published in the Federal Register on the Long Term




Remediation List.  They would not be placed there until the need for such



remediation activities was clearly established by the site assessment function.



Many sites would already have been addressed under the Early Action phase,




eliminating the need to evaluate many of the issues that hold up RODs today.




Enforcement opportunities would be vigorously pursued using the full arsenal of

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                                     -12-
      Enforcement tools to obtain PRP participation. Community Relations would be



      performed and public participation fostered.  Innovative technologies and



      standardized cleanups would be used, as appropriate.  Of greatest benefit, the




      public would understand that the actions placed on this list would require many



      years, if not decades, to clean up, but would pose no immediate threat at all to



      existing populations. Removing the ground water restoration question to a




      separate part of the decision making process would also allow for a more



      reasonable evaluation of the benefits and costs of such restoration. Public  policy



      makers could then more reasonably decide which ground water resources warrant



      priority action given limited funding.








Implementation








   This concept has been developed in Headquarters and discussed with several



Regions.  The next step is to hypothetically run some sites through the proposed process



and see if there are any unforeseen "stoppers." After receiving Agency management




approval, as well as DOJ endorsement, appropriate White House, OMB and




Congressional contacts would be briefed.  The next step would be tested on a pilot basis



in one or two Regions.  Various Regional pilots are being reviewed for utility in the



execution of the process. The timing is very opportune considering the congruence of



current recommendations for improving and streamlining Superfund.

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                                      -13-
 Conclusion




    A program guaranteeing prioritized public health protection at all sites, without

 programmatic distinction, within five years of site identification, and having, as a separate

 activity, the long and difficult job of environmental media restoration, has a better

 chance of being understood, appreciated, and, therefore, publicly supported.




    Counting the totality of risk reduction rather than focusing on NPL site deletions, is

 a simple,  uncontrived, and true expression of the work of the program. It fulfills several
                         .'
 of our most basic needs in building public confidence. First and most important, it

 focuses the program on the very substantial risk reduction that is now achieved, and

 achievable. Second, it focusses on the distinction between sites with the risk reduced to

 safe levels because of completed surface cleanup and those  sites presenting no

 immediate threat, but requiring decades to complete. And  third, it supplies what the

public expects, and has every reason to expect from a program called "Superfund" - the

achievement of appropriate cleanup at large numbers of sites.

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SUPERFUND ACCELERATED CLEANUP MODEL - SACM
                 (The New Superfund Paradigm)
                     March 1992
                             U.S. Environmental Protection Agency
                             OSWER/OERR

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              WHAT'S THE PROBLEM?
1.   Outside perception of Superfund is poor
    •  Too slow
    •  Scanty environmental improvement
    •  Not enough $$ in cleanup.

2.   Internal Superfund process is inefficient
    •  Redundant
    •  Pokey
    •  Too much "cool down" time.
                        ••{ V&7 \ u-s- Environmental Protection Agency

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              THE CURRENT SUPERFUND PROCESS
PRP search/notification
SITE DISCOVERY/
NOTIFICATION


PA
      End response or
      refer to remedial/
       State program
                                                                            I SITE DISCOVERY |

                                                                              .  T  _
                                                                              | PA/FSI/ESIJ
                                                                                 JL
                                                                                MRS
Yes
) ^
not *""
immediate
Expanded
SI
(ESI)

>,

MRS
Package

^

Public
Notification






NPL
f


Rl
1
f
FS


ROD



                                                                                        Public
                                                                                      Notification
                                                                                      Public
                                                                                    Notification
                                    Enforcement Activities
                          State/Public Participation/Community Relations

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             WHAT'S THE SOLUTION?
MAKE SUPERFUND WORK BETTER

1.   Provide results the public will value
    •   Quickly reduce acute risks
    •   Restore environment over long-term,

2.   Streamline program
    •   Eliminate delays and rework
    •   Expand "worst first"
    •   Funnel $$ into cleanup.
                              U.S. Environmental Protection Agency
                              OSWER/OERR

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                HOW DO WE DO IT?
1.   One step site screening and risk assessment.


2.   Regional Management Teams "traffic cop" all sites.


3.   Early action to reduce immediate risk.


4.   Long-term cleanup to restore environment/media.


Enforcement, community relations, and public involvement
throughout process.
                               U.S. Environmental Protection Agency
                               OSWER/OERR

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          1. ONE STEP ASSESSMENT
Streamlined assessment will speed cleanup.
Also blends removal/remedial cultures (action vs. study).
Enforcement search and notification starts immediately.
Community outreach and public involvement throughout.
                             U.S. Environmental Protection Agency

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    2. REGIONAL MANAGEMENT TEAMS
Unite management experience - removal, remedial, enforcement,
assessment, community relations, State involvement.
Serve as "traffic cop" for sites moving to Early Action or
Long-Term Action List.
Prioritize workload to achieve common goal of risk reduction,
Help develop standard cleanups and technologies.
                        •®
U.S. Environmental Protection Agency
OSWER/OERR

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                 3. EARLY ACTIONS
   All immediate threats to public health and safety will be
   eliminated.
   Public will be notified when Early Action starts and notified
   when work is complete.
•  Substantial risk reduction in a short timeframe will be our
   primary measure of success.
                                U.S. Environmental Protection Agency
                                OSWER/OERR

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                 4. LONG-TERM ACTION
   Long-term actions:
    -  extensive mining sites
    -  ground-water remediation
-  estuarine/bay sites
-  incineration.
•  These would be published in FR on the Long-Term Action List.
   The public would know long-term actions require years to clean up,
   but pose no immediate threat.
•  Allows more reasoned evaluation of restoration benefits and costs.
                                  U.S. Environmental Protection Agency
                                  OSWER/OERR

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               WHAT'S DIFFERENT?
ALL SITES OR RELEASES with Superfund cleanup action are
"Superfund sites."
We stopped seeing Superfund as separate programs:
 -  Removal/Remedial
 -  Fund/Enforcement
 -  NPUNon NPL.

No separate list of removal actions and remedial actions.
One simple goal of prioritized risk reduction from all Superfund
cleanups.
                              u s Environmental Protection Agency
                              OSWER/OERR

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                   ADVANTAGES
   Rapidly reduces majority of risk from Superfund sites - to people
   and the environment.
   More money dedicated to cleanup - versus support/study function,
•  Efficient and effective - geared for results.
   Cost and time efficient - emphasizes standard remedies and
   innovative technologies.
   Realistically achievable - commit and deliver.
                              U.S. Environmental Protection Agency
                              OSWER/OERR

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                     BENEFITS
Measures success by risk reduction, not NPL completions.
Makes long-term restoration a separate activity.
Builds public confidence:
 -  Substantial risk reduction in early actions
 -  "Worst first" approach
 -  Cleanup at a large number of sites.
In sync with Agency management themes.
                             U.S. Environmental Protection Agency
                             OSWER/OERR

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                   THE NEW STREAMLINED PROCESS
                       Public Notification of Early Action Start
                                   Early
                                  Action
                              To Reduce Risk

                                (<5 Years)
                                    I
                                 Issue Order/
                                  Negotiate
 All
Sites
Start
 PRP Search
    Site
 Screening
     &
Assessment
            No
           Action
                                                            Public Notification
                                              Issue Order/
                                               Negotiate
                                                               Early Action
                                                               Completed
                                 Regional
                            Decision/Management
                                   Team
Long-Term
 Hazard
 Ranking
                           RCRA
                             or
                        Other Authority
   Long-
   Term
  Action
    for
  Media
Restoration

 (>5 Years)
Delete
                                                                                          Long-Term
                                                                                          Cleanup
                                                                                          Completed
                                        Enforcement Activities
                              State/Public Participation/Community Relations
                                                                                                   13

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NEXT STEPS FOR ACCELERATED MODEL
       Outreach to interested groups.
       Revitalization Team guides Regional efforts.
       Deploy on pilot basis in several Regions.
                         i U.S. Environmental Protection Agency
                      ^y OSWER/OERR

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