&EPA
Office of Solid Waste and Emergency Response
Superiund Revitalization Office. OS-100
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
(OS-100)
Publication 9202.1-03FS
June 1992
Regional Pilots and
Applications of Superfund
Accelerated Cleanup
Model (SACM)
Quick Reference Fact Sheet
CURRENT STATUS OF REGIONAL PILOT PROGRAMS
Overall Status of Regional Pilots:
- 27 Regional Pilots have been approved, including 10 that
address the new Superfund Accelerated Cleanup Model (SACM).
- Pilots address about 60 sites, half of which are short-term
site assessments under SACM.
- Expect results from most pilots over the next 6 to 18 months.
Major Categories of Pilots are:
- SACM: 10 pilots addressing 32 site assessments and 4 early
actions.
- "Presumptive Remedies'VStreamlined Remedy Selection: 3
pilots addressing 6 site types.
- Early Enforcement: 10 pilots addressing 13 - 16 sites (dc
minimis. voluntary cleanups, PRP searches and incentives).
SACM PILOTS
The Superfund Accelerated Cleanup Model (SACM). a new
paradigm governing Superfund site cleanup, will integrate com-
mon elements of the current site assessment, removal and reme-
dial processes. Under the new model, assessment activities will
be consolidated to support both short-term cleanup actions and
long-term remedial actions. Regional Decision Teams will decide
whether a response is required and the type of response. Early
actions will typically require less then 5 years lo complete, and
would address all immediate threats to human health and the
environment. Long-term actions will be reserved for sites with
severe contamination, whose remediation is likely to exceed 5
years. Incentive funding has been approved for ihe following
Regional pilots that test the recently introduced SACM.
Region 1 expects to accelerate the Superfund process through
its START initiative. The down time prior to the start of the
remedial investigation/feasibility study (RI/FS) at NPL sites will
be used to develop technical strategies that wiU allow the RI/FS
work plan to be more specific, focus investigations towards more
promising remedial alternatives, and identify appropriate use of
early action removal authorities. Decision Teams will also be set
up to speed theassessmentprocessat 10 more NPL sites in Region
I.
Similar pilots will be put in place in Regions 2 and 8 that aim
to combine and streamline the expanded site inspection (ESI) and
RI/FS, and complete the work by the time a site is proposed for the
NPL. For these pilots, the Regions will select high priority Fund-
lead sites (likely to score over 28.S on the HRS). At the sites, a
single ARCS contractor will perform the ESI and RI/FS activities
while simultaneously preparing the HRS package, eliminating
breaks in the flow of the site cleanup and allowing the Regions to
achieve economies of scale in the process. Early plume movement
identification at groundwater contamination sites will be one of
the potential benefits of this Region 2 pilot Region 9 will
undertake an assessment of 30 sites to evaluate the feasibility of
combining SI and RI activities. Thisassessment will have the goal
of identifying various sampling activities and investigations that
will meet multiple program needs.
An interdisciplinary team in Region 3 will be used to develop
and implement an approach for evaluating NPL sites for early
actions. The team will develop a questionnaire to be used to screen
sites and criteria for determining which program authorities and
funding mechanisms can be used at candidate sites. Region 3 will
also undertake a thorough management review to identify oppor-
tunities for completions, and will establish a Site Completion
Coordinator who will implement strategies ranging from reducing
required actions to developing incentives for PRPs to reduce
project times.
A team approach for site screening and assessment will be
implemented in Region 5. This approach is expected to accelerate
the cleanup process by combining the sampling needs of the
various program elements.
Region 6expects to shorten the overall Superfund process for
both Fund- and RP-lead sites by combining the techniques now
being used in the Lightning ROD pilots with the integration
themes of SACM (such as an emphasis on Regional management
teams). Remedial actions will start in the year following site
identification on the NPL. and the National Zinc at Bartlcsville
site will serve as a model in this process.
Region 10 expedited cleanup using removal authority at the
Yakima Plating site and two NPL sites. These cases require
surface contamination removal, but no groundwater restoration.
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EARLY ENFORCEMENT PILOTS
Region 1 will explore and demonstrate innovativeapproaches
to structuring the Statement of Work (SOW) that accompanIes
consent decrees at selected pilot sites over the next SIX to eight
months. Restructuring the SOW may result in more timely P92
remedies by providing incentives and disincentives in the RD/RA
negotiation process for completing cleanup ahead of schedule.
In the Laurel Park/Beacon Heights case, early enforcement
iniuativcs will be used to accelerate settlements with third party
municipal solid waste entities. Approximately 1,200 letters will
be sent and research conducted on about 800 parties.
In order to develop a single settlement proposal for negotia-
tions, Region 3 is planning a proactive settlement with 551 d c
nnmnus panics at the Tonolli Corporation site. The Region will
send a letter with the waste-in list to the de mbthnis group
announcing a “kick off’ meeting and encouraging the parties to
organize and establish a steering committee.
Reducing”dead time” between the ROD and the RD/RA part
of the pipeline is the purpose ofenforcement strategy meetings to
be held in Region 3. With the results of these meetings, the Region
will enter negotiations having addressed the following:
- PRP search preparedness;
- incorporation of performance review standards into RODs;
- expanded use of removal authorities at NPL sites
An “enforcement first” program is being implemented in
Region 4 at the Greenback Industries site and two other sites. The
Region combined ESI and RI/PS activities into one PRP-lead
even t,and is being performed simultaneously with the NPL listing
activities. The majorbenefitofthisstrategy will be voluntary PRP
cleanup (under an administrative order on consent) with EPA
oversight. Region 4 is also starting apilotat Aquatech on early de
ininunis settlements concurrent with on-going removal and en-
forcement activities.
In Region 8, the PRP is willing to clean up the Kennecott
Mine site and address all other environmental issues in order to
continue operating the mine for the remaining years of its life. The
final productofthenegotiations isanticipatedtobean enforceable
ce!’sentdecreein which Kennecott will perform the investigations
and all cleanup with oversight by EPA and the slate.
Another pilot in Region 8 is planned for the Annie Creek site.
The Region intends to use both Superfund and Clean Water Act
authorities in a cross-media project to expedite cleanup at the site.
Based on a list of potential incentives for PRP5 to settle
quickly and proceed to early RD and cleanup, Region 8 adniinis-
uat s and managers willcoordinate with various EPA offices and
)J to aj”n” these incentives at three to five pilot sites. The pilot
may ,tsut ui identifying incentives that may be useful at similar
sites.
RDIItA activities at the Operating Industries, Inc. site in
Region 9 will be accelerated by pressing for an early settlement
with the 3,500 de minimA: PRPs. The Region will notify the
parties of liability and negotiate remedy implementation by the
end of 1993, possibly setting precedents for size, monetary value,
and timeframe if a de minimis settlement of this nature can be
achie red.
In Region 10, a pilot is planned to improve the quahty arid
timeliness of PR? searches to address the “perception of fairness”
issue in enforcement activities and settlements. The Region wilt
make available its recommendations for streamlining the PR ! ’
search process and addressing equit ) issues in the enforcement
program.
PRESUMPTIVE REMEDY PILOTS
To streamline the cleanup process, Regions are piloting a new
approach to remedy selection. Grouping sites by characteristics,
such as contamination and geology, Regions will compile lists of
successful, or “presumptive”, remedies. “Ibis new approach will
allow the standardization of cleanup goals. RODs, Statement of
Work (SOW) language, and nsk assessment scenarios. These
“presumptive remedies” are being tested in several Regions at
pilot sites to evaluate their success.
Standardized RODS may be used in Region 9w accelerate the
cle. nup at a site near Phoenix. Similar contamination and
geology at the northern (NIBW) and southern (SLEW) sections of
the Indian Bend Wash site provide a good setting for this pilot as
the RODS developed for the operable units (OUs) at the NIBW site
are almost directly applicable to the SIBW site. The Region plans
to use the RODs and alternatives analysis developed for soil and
groundwater VOC contamination at NLBW to quickly create new
RODS for the OUs at the 513W site.
Region 7 proposes to develop standard cleanup goals, remedy
types, ROD and SOW language, and risk assessment scenarios for
grain storage sites, PCB sites, and coal gasification sites. Pilot
sites will be selected forapplication of the standardsand a process
will be developed to update the standards as science and regula-
tions change.
Region 6 is piloting a project that will shotlen the RI/PS
timeframe by 75 percent at three sites. The Region will achieve
this reduction by drawing on previous experience with similar
sites to conduct a focused PS ann standardize certain design
elements. This approach is being piloted at the Popile l .,West
Memphis Landfill, and American Creosote sites.
OThER PILOTS
Three regions have introduced innovative projects that aim to
improve the Superfund program in general.
An Outreach Specialist will be employed in Region 10 to
impart the accomplishments of Superfundto the public, the press,
Congress, and interested groups. The goals of the pilot are to
improve communications and to open an avenue to counter
criticism of the program.
Region 3 is focusing on improvements in the Contract labo-
ratory Program. The Region is updating data protocols and
streamlining documentation, providing training to private sector
labs, and producing a guidance document for data audits. Region
8 isplanningapilotthatwillaccelerateFy93compith Using
referrals to stare authorities, expedited PS for soil contamination,
greater use of removal authorities, arid working with willing
PRPs, Region 8 anticipates accomplishing an additional 5 comple-
tions in FY93. The pilot programs will be incorporated into work
at the following sites: Williams Pipe Line, Denver Radium,
Mystery Bridge, Broderick Wood,, and Chemical Sales,
n
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