United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
Washington, DC 20460
2d Edition, 1983
Superfund's Remedial
Response Program
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Superfund's
Remedial
Response
Program
The blueprint for the Super-
fund program under the
Comprehensive Environmen-
tal Response, Compensation,
and Liability Act of 1980
(CERCLA) is the National Con-
tingency Plan (NCR), first pub-
lished in 1968 as part of the
Federal water pollution control
program. CERCLA ordered re-
vision of the NCR to provide
new Federal authority to re-
> spond to the problems of
j abandoned or uncontrolled
hazardous waste disposal sites
and to a greater range of
hazardous substances than
previously controlled. In con-
sultation with 13 Federal agen-
cies, EPA published the NCR in
final form on July 16,1982.
Oil spills will continue to be
handled as they have been in
the past. For spills threatening
coastal waters, the Coast
Guard takes the lead respon-
sibility; for inland spills, EPA
takes the lead.
TheCERCLA-basedNCP
lays out three types of respon-
ses for incidents involving
hazardous substances.
Immediate removal, which
requires prompt response
to prevent immediate and
significant harm to human
life, health, or the environ-
ment. Generally, immediate
removals must be com-
pleted in 6 months or after
expenditure of $1 million.
Planned removal, which is
needed when an expedited,
but not necessarily im-
mediate, response is re-
quired. The 6-month or $1
million-limitation also applies.
These two types of re-
sponses are modifications of
the earlier program under the
Clean Water Act. The third is a
new type of response in-
tended to deal with the
longer-term problem of aban-
doned or uncontrolled sites:
Remedial response, which
requires more time and
money and is intended to
achieve a solution consist-
ent with permanent rem-
edy. EPA, in partnership
with the States, takes the
Federal lead in all remedial
response actions, coordinat-
ing its activities with the 13
Federal agencies involved
in the NCR The agencies
most often called upon are
the Federal Emergency
Management Agency, De-
partment of Health and
Human Services, and De-
partment of Justice.
Cleanups financed by pri-
vate industry such as this
one at the Chem-Dyne site
in Hamilton, Ohio are im-
portant for augmenting the
Trust Fund. EPA negotiated
an agreement in which 112
parties responsible for
hazardous wastes at the
site will pay $2.4 million
toward the cost of surface
cleanup.
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Discovery/Screening
A
Initial Planning
Evaluation
(Preliminary
Assessment
and
Site Inspection)
Remedial
Investigation
Ranking
Feasibility
Study
Selection
of
Remedy
Remedial
Design/
Construction
(Process
Choosing the appropriate
remedy is a lengthy process.
First the problem must be de-
fined. Then the remedial ac-
tion must be planned in detail.
EPA's Office of Emergency and
Remedial Response, working
closely with its Regional Of-
fices, tailors each remedial re-
sponse to the specific needs of
the site.
Defining the problem in-
volves three steps. First the
site must be discovered and
screened according to specific
criteria. Then it is evaluated
and ranked according to
guidelines in the NCR
Discovery/Screening
EPA learns of hazardous
waste sites through a variety
of ways. Some have been
identified through other EPA
programs for example,
those under the Safe Drinking
Water Act and RCRA. EPA Re-
gional Offices and many
States have compiled inven-
tories of sites in their jurisdic-
tions. Also, CERCLA required
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that owners or operators of
facilities handling hazardous
substances notify EPA by June
1981 of their activities. This
process identified about 9,000
sites, many of them already
known to EPA. Concerned citi-
zens also called the toll-free
number of the National Re-
sponse Center to report sites.
EPA screened these various
sources of information and
consolidated them into an
inventory of currently over
16,000 potential sites where
hazardous substances are
stored, treated, or disposed of
in an unregulated manner.
Site evaluation involves a
sequence of investigations to
determine the extent of con-
tamination at a site and to
provide a data base sufficient
to identify the most appropri-
ate response. This could be:
no further action, additional
investigation, emergency re-
sponse, development of an
enforcement action, or reme-
dial response.
The following steps are
taken to investigate at least
cost the hazards at a site:
Preliminary assessment:
collection and review of all
information available for a
given site to evaluate the
source and nature of the
hazardous substances pres-
ent and to determine if a
responsible party can be
identified.
Site inspection: Various
degrees of on-site investiga-
tions conducted to deter-
mine the extent of the prob-
lem and to gather the data
needed to set priorities. The
emphasis is on contamina-
tion pathways that affect
human health. A typical site
inspection involves sam-
pling, surveying, monitor-
ing, reconnaissance, and
other field activities to de-
fine the problem. It may in-
volve a hydrogeological and
geological assessment.
These investigations be-
come the basis for a report
that identifies types of
wastes present, estimates
their amounts, and de-
scribes how they are stored
or disposed of; proposes a
safety plan to protect in-
spectors and nearby resi-
dents; and evaluates the
impact on the area around
the site.
Hazardous waste sites are
evaluated primarily by Field
Investigation Teams stationed
at the EPA Regional Offices.
These teams are staffed by
over 230 trained professionals
with a breadth of technical
skills.
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Ranking
CERCLA calls for compiling
a National Priorities List of at
least 400 hazardous waste
sites as candidates for remed-
ial action. The data gathered in
the evaluation process provide
the basis for ranking the sites,
taking into account these
criteria:
o Possible risk to the
population
o Hazard potential of sub-
stances at the site
o Potential for contaminating
drinking water supplies and
other pathways that affect
human health
o Potential for destruction of
sensitive ecosystems
EPA also evaluates the need
for removal actions at sites
posing immediate threats to
health or the environment.
The potential for direct con-
tact, fires, and explosions is
given special consideration.
In October 1981, EPA compiled
an Interim Priorities List of 115
hazardous waste sites. They
were nominated by the EPA
Regional Offices and the
States, primarily on the basis
of potential threat to public
health, but the threat to the
environment was also taken
into account. In addition, each
State was encouraged to des-
ignate its top priority site. A
State or Region rated each site
it nominated according to a
Hazard Ranking System,
which measures pollution via
three pathways air, ground
water, and surface water for
potential impacts.
In July 1982, with some kind
of action under way on almost
all of the 115 sites, EPA added
45 new sites to the Interim List.
All 160 sites on the Interim List
were considered for inclusion
on the National Priority List
(NPL). In December 1982, EPA
proposed a list of 418 sites in
the Federal Register. The sites
were identified by the same
process used to develop the
Interim List. On March 4,1983,
Times Beach, Missouri, was
added.
In September 1983, EPA
published the first final NPL,
which consisted of 406 sites.
At the same time, 133 new
sites were proposed for addi-
tion, meeting the CERCLA re-
quirement that the list be up-
dated at least annually.
A priority site can be
cleaned up in several ways:
o The responsible party can
clean it up voluntarily.
o The State or local govern-
ment can choose to assume
all, or almost all, of the re-
sponsibility to clean it up
without tapping the Trust
Fund.
o The responsible party may
be forced to clean it up by
legal action.
o The Trust Fund may be
used to finance the cleanup
if the site cannot be cleaned
by any of the first three al-
ternatives. If there are prob-
lems in getting the respon-
sible party to act, EPA will
proceed under Superfund
and seek later to recover
costs by legal action.
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Superfund in the Field
Council Bluffs, Iowa
The Aidex Corp. site in
Council Bluffs is the top-
priority site in Iowa. Man-
agement practices at a
now-abandoned plant for
formulating and packaging
pesticides had left a large
quantity of liquid and solid
pesticide material scattered
about. A fire in 1976 wors-
ened conditions by exten-
sively contaminating the soil
with water used in fighting
the fire. To ensure the safety
of workers on site, EPA's
Field Investigation Team,
wearing protective gear,
checks the air for volatile
organic compounds.
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Detailed planning is neces-
sary if EPA is to make rapid,
consistent, and rational deci-
sions in implementing reme-
dial actions under Superfund.
The objective is to determine
the "appropriate extent of
remedy"the least expensive
remedy that is technologically
feasible and reliable, effec-
tively reduces the danger, and
adequately protects public
health, welfare, and the envi-
ronment. The planning proc-
ess consists of these elements:
0 Initial planning
o Remedial investigation
o Feasibility study
o Selection of a remedy
o Remedial design/
construction
Initial Planning
Determining the scope of
prospective remedial activities
is the primary focus of the ini-
tial planning phase. The NCR
identifies three actions, based
on the complexity, immediacy,
and extent of the hazards.
Some or all may be taken at
any one site. The three actions
are:
o Initial remedial measures:
taken when appropriate ac-
tions are limited in nature
and require a minimum of
planning. Examples include
construction offences,
stabilization of dikes or
waste impoundments,
temporary provision of al-
ternative water supplies,
and removal of above-
ground drums or bulk tanks
leaking hazardous
substances.
Source-control actions:
taken when substantial con-
centrations of hazardous
substances remain on-site,
barriers to retard their mi-
gration are inadequate, and
there is a serious threat to
public health, welfare, or the
environment. Examples in-
clude installation of grout
curtains, trenches, and
drains, closure of surface
impoundments, capping of
contaminated areas, and
excavation followed by off-
site disposal of contami-
nated soil or buried waste.
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Superfund in the Field
Verona, Mo.
After receiving an anony-
mous complaint, EPA inves-
tigated a wooded area on a
farm near Verona, Mo. Sus-
pecting the presence of di-
oxin, EPA (in 1979, before the
Superfund law was passed)
undertook a comprehensive
site inspection and discov-
ered a depression now
known as the Denny Farm
Site No. 1. As part of the
inspection, EPA drilled soil
borings around the 10-foot
by 50-foot trench (below),
then dug into it, exposing 13
drums. Analysis confirmed
the presence of dioxin. EPA
then negotiated a cleanup
agreement with a company
that had purchased the fa-
cility responsible for
generating and disposing of
the wastes. In mid-1981, the
company uncovered the
drums and transferred the
wastes to a nearby pit
(right). The trench was filled,
compacted with virgin soil,
and capped. In cooperation
with EPA, the company is
evaluating the best means of
disposing or treating the
materials removed from the
trench.
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° Off-site actions: taken
when source-control meas-
ures are inappropriate or
would not effectively reduce
migration of hazardous
substances from the site.
Examples include perma-
nent provision of alternative
water supplies, control of a
contaminated aquifer,
dredging of contaminated
river sediments, and reloca-
tion of the affected
population.
Because of their limited
scope, initial remedial meas-
ures can be taken during the
planning for additional
source-control or off-site ac-
tions. The initial remedial
measures, however, must be
either cost effectivethat is,
the least expensive alternative
that is technologically feasible,
is reliable, and adequately pro-
tects the environment or a
necessary part of more exten-
sive remedial actions to be
taken later.
In making an initial planning
decision, EPA works closely
with the State. In particular, the
State often provides site data
and other important informa-
tion. Also, the State is given
the opportunity to review and
comment on EPA's planning
efforts.
The planning decisions are
addressed through a Remedial
Action Master Plan (RAMP). In
addition to the scope of reme-
dial activities, the RAMP also
considers project costs and
schedules for anticipated re-
medial activities, as well as the
extent and availability of exist-
ing data.
EPA will also prepare a Site
Management Plan, which
considers all cleanup alterna-
tives, including enforcement
actions and clean up by re-
sponsible parties.
Another important element
of initial planning activities is
the State's decision on the role
it wants to take in the remedial
action (including the IRM).
CERCLA permits two ar-
rangements:
° A cooperative agreement,
in which the State takes the
lead role. A cooperative
agreement is much like a
grant in that Federal money
is transferred to the State.
The State then develops a
work plan, schedule, and
budget, contracts for any
services it needs, and is re-
sponsible for ensuring that
all the conditions of the
cooperative agreement are
fulfilled. In contrast to a
grant, EPA continues to be
substantially involved,
monitoring the State's prog-
ress throughout the project.
EPA encourages coopera-
tive agreements because
they allow maximum State
participation/which is es-
sential to the success of
remedial actions under
Superfund.
o Superfund State contract, in
which EPA takes the lead.
Early in remedial actions,
the work is done by one of
EPA's two major Superfund
contractors. Later phases
are managed by the Army
Corps of Engineers. Under
an interagency agreement,
the Corps provides techni-
cal assistance in the design
and construction of reme-
dial actions. Using Super-
fund monies, the Corps
contracts with private com-
panies for the actual per-
formance of design and
construction.
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Superfund in the Field
Old Forge, Pa.
EPA learned of the Lehigh
Electric and Engineering Co.
site in Old Forge, Pa.,
through an anonymous
source in March 1981. The
site covers 4.4 acres on the
banks of the Lackawanna
River and is immediately ad-
jacent to a residential area
with about 50 homes. Work-
ing with the Pennsylvania
Department of Environmen-
tal Resources, EPA inspected
the site and determined that
the soil was grossly con-
taminated with polychlori-
nated biphenyls (PCB), an
oil-like toxic organic chemi-
cal once widely used as insu-
lation in capacitors,
transformers, and other
electrical equipment. EPA
decided to clean up the
Lehigh site in two phases.
The first was to remove all
equipment and material
from the surface. An EPA
contractor compiled a de-
tailed inventory of all
equipment at the site (be-
low) and sampled each one
(right). Exposed workers
wore protective gear. Phase I
started in July 1982. While it
was under way, engineering
studies started for Phase II,
which will consider the con-
taminated soil on the site.
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Super-fund in the Field
Oswego, N. Y.
Pollution Abatement Serv-
ices (PAS) in Oswego is the
top-priority site in New York.
The 15-acre tract is occupied
by a waste disposal com-
pany that operated a high-
temperature incinerator for
liquid wastes (below) before
going bankrupt in 1977. Dur-
ing the peak period of opera-
tion, the facility reportedly
received over 1 million gal-
lons of wastes per month.
The area immediately
around the site is sparsely
populated, but two small
creeks traversing the
property discharge into Lake
Ontario, less than one-third
of a mile away.
Working under a Coopera-
tive Agreement with the
New York State Department
of Environmental Conserva-
tion, EPA, assisted by a con-
tractor, decided on initial
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remedial measures to re-
move and dispose of all sur-
face materials, including
drums, wastes in drums,
bulk wastes, equipment,
and buildings. This approach
was taken because it could
be contracted for in a short
period of time and did not
require extensive design
work. Also, cleaning up the
surface was necessary to
prepare the site for later field
work to determine the ex-
tent of subsurface
contamination.
The work plan developed
for the initial remedial
cleanup called for the
following:
Identification and review
of all information concern-
ing the site and wastes
present.
Establishment of health
and safety procedures for
future activities on site.
Development of a protocol
for the safe and econom-
ical handling, bulking of
compatible wastes, trans-
porting, and disposal of
the wastes likely to be
encountered.
Sampling to determine
the types of wastes pres-
ent. EPA estimated that
the site held 8,600 drums
containing about 99,300
gallons of waste and 1,200
cubic yards of contami-
nated soils.
Analysis of disposal op-
tions. The only viable op-
tion turned out to be
transportation off-site.
Empty drums were
crushed on site and buried
at a local sanitary landfill.
Drums containing solid
hazardous wastes were
loaded into a truck (left)
and shipped to a permit-
ted land disposal facility.
The truck was then hosed
down with water to de-
contaminate it (below
left). The liquids were
pumped into tanks and
treated at the same per-
mitted facility (below
right).
Layout of the site into
clean and dirty zones
based on level of con-
tamination. The dirty zone
is the controlled area
where the waste is
staged, sampled, bulked
(if appropriate), and
packed for transport.
Development of standard
operating procedures.
Work started on the initial
cleanup in June 1982.
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CERCLA also assigns other
responsibilities to the States,
requiring them:
To share costs of the design
and construction phases of
remedial actions. States
must contribute 10 percent
on sites that were privately
owned at the time of dis-
posal of hazardous sub-
stances and at least 50 per-
cent on sites that were pub-
licly owned.
To finance operation and
maintenance costs, except
for an initial period, when
EPA will share in the cost to
certify that the remedy ac-
tually functions as planned.
To assure that approved fa-
cilities are available to treat,
store, or dispose of any
hazardous substances
transported from the site.
Remedial Investigation
With the State role defined,
the remedial investigation can
begin. It is designed to collect
and analyze the data neces-
sary to justify remedial action
and to support development
of alternatives in the feasibility
study. The scope of the inves-
tigation varies depending on
which of the three types of
remedial action (initial remed-
ial, source-control, and off-site)
is involved. During this phase,
the initial scoping decision
may be revised as additional
information is gathered.
Typically, remedial investiga-
tions involve a sequence of
activities such as:
Preliminary activities for
example, visiting the site,
defining the boundary con-
ditions, preparing a site
map, and establishing an of-
fice on site.
Studies of the wastes, hydro-
geologic conditions, soils,
sediments, ground water,
surface water, and air
quality.
Preliminary identification of
appropriate remedial
technology.
Sampling is an important
part of investigations and
other remedial activities.
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Feasibility Study
The feasibility study, which
is often conducted with the
remedial investigation as one
project, involves several steps:
Development of alterna-
tives, including establishing
objectives, identifying
possible technologies, and
designing specific methods
for cleanup at the site.
Non-cleanup options such
as relocating people or sup-
plying alternative sources of
water, as well as a no-action
alternative, are also
considered.
Initial screening of alterna-
tives on the basis of costs,
effects on health and the
environment, and technical
feasibility
Analysis of the remaining
alternatives in detail.
Recommendation of the al-
ternative offering the most
favorable results at the least
cost.
Development of a prelimi-
nary conceptual design
of the recommended
alternative.
Review of the alternatives
by citizens of the affected
community.
Selection of Remedy
The EPA Regional Offices
and States transmit their rec-
ommendations to the Assist-
ant Administrator for Solid
Waste and Emergency Re-
sponse. In selecting the reme-
dial alternative, EPA must de-
termine the appropriate extent
of remedy. Also, EPA must
consider the CERCLA re-
quirement to balance the need
to protect public health, wel-
fare, and the environment at a
specific site against the
availability of Fund monies to
respond to other sites, taking
into account the need for im-
mediate action.
Remedial
Design/Construction
The last step is to prepare
the remedial design, which
clearly defines the selected
remedy in a bid package, and
implement the design. Formal
advertisement for contracts is
the preferred method for im-
plementing remedial actions.
Therefore, the remedial design
usually results in a set of con-
tract documents, including de-
tailed plans and specifications,
that allow potential contractors
to bid. At sites where EPA has
the lead, the Corps manages
the design and construction
activities.
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Superfund in the Field
Butler County, Pa.
The Bruin Lagoon site oc-
cupies more than 4 acres
along the banks of Bear
Creek in Butler County, Pa.
Its focal point is an open
earth-diked lagoon of about
1 acre containing 35,000
cubic yards of asphaltic
sludge and 130,000 gallons
of liquid acid wastes floating
on top. The site began oper-
ations in the 1930's. In 1968,
a breach in the dike resulted
in a spill of 3,000 gallons of
waste liquid, which killed an
estimated 4 million fish and
closed water-supply intakes
downstream. The dike has
been reinforced, but its sta-
bility remains a concern.
An EPA contractor per-
formed a remedial investiga-
tion and feasibility study for
the site. Sampling of the
sludge (below) indicated
that it is soluble and acidic,
with high levels of oily and
inorganic constituents. To
get samples from the middle
of the lagoon, a worker leans
over the bank (right). As
safety measures, he wears a
protective suit, carries a
supply of oxygen, and is at-
tached to a stationary object
on shore.
The major conclusions of
the remedial investigation
were:
Over its history, much of
the site was used for dis-
posal of petroleum refin-
ing residues.
The site is releasing con-
taminants, primarily inor-
ganic, to both surface and
ground water. Drinking
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water supplies do not ap-
pear to be affected.
After evaluating the ana-
lytical data from samples
collected at Bruin Lagoon,
EPA decided to focus on
source-control measures.
The objectives were to pre-
vent catastrophic failure by
stabilizing the dike and to
eliminate the threat to pub-
lic health and the environ-
ment by preventing wastes
from migrating into surface
and ground water. Eleven
remedial action strategies
were identified and evalu-
ated on the basis of meeting
the major objectives. An ini-
tial screening eliminated
seven, leaving three on-site
options (containment, en-
capsulation, or fixation of
waste) and excavation fol-
lowed by off-site disposal. A
"no-action" alternative was
also considered.
After reviewing the reme-
dial investigation and feasi-
bility study, EPA and the
State selected waste con-
tainment as the lowest-cost
alternative that met the de-
sired objectives. This alter-
native called for action to:
Clean up site in general
Remove and dispose of
acidic liquid
Excavate and dispose of
contaminated soil
Stabilize sludge in situ
Construct multilayer cap
Cover, regrade, and re-
vegetate
Secure site
Monitor and maintain site
After the feasibility study
was completed, the contrac-
tor undertook three addi-
tional tasks:
Development of an En-
vironmental Impact
Assessment.
Evaluation of the stability
of the dike. The conclusion
was that minor slope im-
provements and surface
erosion controls would
stabilize the dike during
and after lagoon closure.
Bench-scale tests to eval-
uate the effectiveness of
various techniques for
stabilizing sludge so that
the lagoon will be able to
support the multilayer
cap.
EPA awarded a contract to
implement the remedy in
August 1983. Construction is
expected to be complete by
spring 1984.
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The success of any Super-
fund remedial action depends
in large measure on support
of the local, affected public.
Consequently, a community
relations program is an inte-
gral part of every remedial
action.
When a site is designated
for funding, one of the first
things EPA does is to meet
with local officials, civic lead-
ers, and community residents
in order to gauge their con-
cerns and information needs.
These discussions form the
basis of the community rela-
tions plan. The plan estab-
lishes how the public will be
kept informed about activities
at the site and how public
input will be obtained. A key
focus of input from citizens is
the 3-week public comment
period on the draft feasibility
study. The feasibility study
specifies the options which
EPA is considering for the
long-term remedial cleanup.
A community relations plan
is flexible and tailored to the
characteristics of the site and
the needs and concerns of the
surrounding community.
Superfund's remedial action
program is designed to deal
with the worst uncontrolled
hazardous waste sites where
responsible parties do not
clean up. The remedial pro-
gram addresses poor waste
management practices of the
past, while RCRA manages the
hazardous wastes generated
now and in the future.
EPA and the States have
initiated a very strong RCRA
program requiring financial
and technical commitments,
with mandatory reporting re-
quirements designed to en-
sure safe handling, storage,
transportation, and disposal of
hazardous wastes. This pro-
gram built on knowledge
gained from the past will
help the Nation avoid a repeti-
tion of mistakes and encour-
age the development and
refinement of new, more effec-
tive waste technologies. In
short, Superfund will clean up
past mistakes, RCRA will pre-
vent new ones.
16
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EPA Superfund Offices
REGION 1
Director
Waste Management Division
John F. Kennedy Building
Boston, MA 02203
CML: (617) 223-5186
FTS: 223-5186
REGION 2
Director
Air & Waste Management Division
26 Federal Plaza
New York, NY 10278
CML: (212) 264-3082
FTS: 264-3082
REGION 3
Director
Air & Waste Management Division
6th & Walnut Streets
Philadelphia, PA 19106
CML: (215) 597-8131
FTS: 597-8131
REGION 4
Director
Air & Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365
CML: (404) 881-3931
FTS: 257-3931
REGIONS
Director
Waste Management Division
111 West Jackson Boulevard
Chicago, IL 60604
CML: (312) 886-7579
FTS: 886-7579
REGION 6
Director
Air & Waste Management Division
1201 Elm Street
Dallas, TX 75270
CML: (214) 767-2730
FTS: 729-2730
REGION?
Director
Air & Waste Management Division
324 E. 11th Street
Kansas City, MO 64106
CML: (816) 374-6864
FTS: 758-6864
REGIONS
Director
Air & Waste Management Division
1860 Lincoln Street
Denver, CO 80295
CML: (303) 837-2407
FTS: 327-2407
REGION 9
Director
Toxics & Waste Management
Division
215 Fremont Street
San Francisco, CA 94105
CML: (415) 974-7460
FTS: 454-7460
REGION 10
Director
Air & Waste Management Division
1200 6th Avenue
Seattle, WA 98101
CML: (206) 442-1352
FTS: 399-1352
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