United States Office ol Solid Waste Publication 9202.1-021

Environmental Protection and Emergency Response September 1992

Agency (OS-100]
#EPA
Smart Moves in Superfund -

Regional Pilots and Initiatives
Periodic Bulletin

Published lor Superfund Headquarters
and Regional Personnel
Volume 1, Number 2
SACM TO STREAMLINE CLEANUP
EPA's Office of Emergency and Remedial Re-
sponse (OERR) is initiating the Superfund Accelerated
Cleanup Model (SACM) to speed and streamline the
cleanup process. This model involves four steps.
(1)	Combine the multitude of current site assessment
steps into a single process, thereby removing
redundant features of that process.
(2)	Create "Regional Decision Teams" to prioritize
sites and to select appropriate action.
(3)	Address immediately and comprehensively those
sites that pose the greatest threat to public health,
notifying the public when these "Early Action11
starts begin and end, and using these sites as a
primary measure of success.
(4)	Create a list of "Long-term Action" starts for those
sices that will require lengthy remediation (e.g.,
sites with extensive groundwater contamination),
explaining to the public that these sites will take
years to be cleaned up but pose no immediate
Threat to health.
OERR is working with the Office of Waste
Programs Enforcement and the Superfund Revitaliza-
lion Office to pilot SACM during FY 92 and FY 93.
The strength of SACM is its ability to improve the
cleanup system without diminishing important elements
of the current system These elements include early
enforcement activities, public participation, and State
involvement.
SACM will focus funds on cleanup and assess-
ments that support the goal of cleanup. A premium will
be placed on blending the four "cultures" involved in
site cleanup - the removal, pre-remedial, remedial, and
enforcement staff - to allow for "Early Action" starn to
be more widely understood and accepted.
IN THIS ISSUE
SACM to Streamline Cleanup	1
SACM Planning Session	1
Regions Test SACM	2
Suggestion Box	2
Six Regions Accelerate Cleanup
Through Early Enforcement	3
Presumptive Remedies Used in
Three Regions to Speed Cleanup	3
Pilots That Are Not Sue Specific	„.„4
Branch Chief Conference Calls		4
SACM PLANNING SESSION	
On April 14-16, Regional and Headquarters
managers met to discuss the implementation of the
Superfund Accelerated Cleanup Model (SACM). The
focus of this meeting was to understand and resolve the
issues involved in accelerating the Superfund cleanup
process and implementing the SACM approach. These
issues include
Further combining the assessment process,
Clarifying the distinction between early action and
long-term action, and
Identifying necessary program management and
contractual changes.
Discussions were targeted at developing a well-
defined framework for implementation of SACM.
Discussion groups defined the implementation plan,
addressing when implementation will begin, how the
Continued on Page 2
Sponsored by the Superfund Revaluation Office (SRO). this bulletin serves as an exchange for Regional
information on activities to streamline Superfund. The SRO reports to »tchard Gutmond. Deputy Assistant Adminis-
trator for OSWER. and is directed by Tim Fields

-------
SUGGESTION BOX	
As you come up wiih new ideas on Superfund
Revitalization or preliminary findings from your
pilots and other lniuauves, wc want to hear about
them and so do the other Regions. This is not
necessarily a forum for official policy, but an
opportunity to exchange thoughts on streamlining
the process. Please send your suggestions to Jan
Young, HQ, OS-lOO, Room 2827, (202) 260-1691.
REGIONS TEST SACM
Incentive funding has been approved for the
following Regional pilots that test the recently intro-
duced Superfund Accelerated Cleanup Model (SACM).
Through the START initiative. Region 1 hopes to
take advantage of the down ume prior to the start of the
remedial investigation/feasibility study (RI/FS) at NPL
sites in order to accelerate the Superfund process. This
ume could be used to develop technical strategies that
will 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. Region 1 will also apply the
decision team assessment process to 10 more NPL sites
Region 2 and Region 8 plan similar pilots that aim
to combine and streamline the expanded sue inspection
(ESI) and RI/FS, and complete the work by the time a
site is proposed for the NPL. The Regions will select
high priority Fund-lead sites (likely to score over 28.5
on the HRS) to test this strategy. At the sites, a single
ARCS contractor will perform the ESI and RI/FS
activities while simultaneously preparing the HRS
package. Region 2 suggests that this pilot may be
effective at groundwater contamination sites because
early identification of plume movement is possible.
A previously approved pilot in Region 3 is another
example of a SACM test pilot. The Region is assem-
bling an interdisciplinary team to develop and imple-
ment an approach for identifying NPL sites where
removal and remedial action car be integrated. 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 6 is combining the techniques now being
used in the Lightning ROD pilots with (he integration
themes of SACM (such as an emphasis on Regional
teams) to shorten the overall Superfund process for both
Fund- and RP-lead sites by five years. Remedial
actions wilt start in the year following site placement on
the NPL.
Region 10 plans to conduct the response action
through the removal program at the Yakima Plating
site. The site is small (three acres) and (he metal
contamination is well characterized. The surface soil
contamination can be handled by excavation and
disposal. Region 10 also has pilots at two NPL sites
that require surface contamination removal, but no
groundwater restoration. Cleanup could be expedited
by conducting removal actions following the comple-
tion of the RI and risk assessment. In place of a ROD,
the Region will prepare an action memorandum.
Additional SACM pilots are being initiated in
Region S, Region 6, and Region 9. More information
on these pilots will be included in the next bulletin.
For further information on these pilots, contact
Dennis Huebner in Region 1 at FTS 833-1610, Vincent
Pitruzzello in Region 2 at FTS 264-3984, Thomas C.
Voltaggio in Region 3 at FTS 597-8181, Carl Edlund in
Region 6 at FTS 255-6664, Paul S. Arell in Region 8 at
FTS 330-7658, or Carol Rushin in Region 10 at FTS
399-7151.
SACM PLANNING SESSION	
Continued from Page 1
program will be implemented, and who will be respon-
sible for the implementation stages. The implementa-
tion plans were presented to Don Clay, Assistant
Administrator of the Office of Solid Waste and Emer-
gency Response at a plenary session on April 16. Don
Clay expressed his commitment to and support for the
SACM implementation process.
Finally, before adjourning, the implementation
team reviewed the next steps in the long-term imple-
mentation of SACM. These include
•	Developing an on-going communications strategy.
Establishing a standing committee of Headquarters
and Regional members to address the implementa-
tion process, and
•	Initiating a process for evaluating the successes of
SACM implementation.
2

-------
SIX REGIONS ACCELERATE CLEANUP THROUGH EARLY ENFORCEMENT
Six Regions arc developing innovative approaches in
the areas of enforcement and voluntary cleanup that are
being piloted in the Supcrfund program.
Over the next six to eight months. Region 1 is
restructuring the Statement of Work (SOW) that accom-
panies consent decrees at selected pilot sites. Restructur-
ing the SOW will provide incentives and disincentives in
the RD/RA negotiation process, resulting in more timely
PRP remedies. Discounts or oversight costs or financial
incentives for completing cleanup ahead of schedule are
examples of the types of incentives proposed.
Region 3 is planning a proactive settlement with 551
de minimis partes at the Tonolli Corporation site. The
Region will send a letter with the waste-in list to the de
minimis group announcing a "kick off meeting and
encouraging the parties to organize and establish a
steering committee. The purpose of the committee is to
develop a single settlement proposal for negotiations.
Region 4 is implementing an "enforcement first"
program at the Greenback Industries site and two other
sites. The Region combined ESI and RI/FS activities into
one event led by the PRPs. The ESI/R1/FS work is being
performed simultaneously with the NPL listing activities.
Voluntary PRP cleanup (under an administrative order on
consent) with EPA oversight is the major benefit of this
strategy. Region 4 is also starting a pilot at Aquatech on
early de minimis settlements concurrent with on-going
removal and enforcement activities.
In Region 8 negotiations, the PRP is willing to clean
up the Kennecou Mine site and address all other environ-
mental issues in order to continue operating the mine for
the remaining years of its life. The final product of the
negotiations is anticipated to be an enforceable consent
decree in which Kennecolt will perform the investiga-
tions and all cleanup with oversight by EPA and the
State.
Another pilol in Region 8 is planned for the Annie
Creek site. The Region intends to use both Supcrfund
and Clean Water Act authorities in a cross-media project
to expedite cleanup at the sue.
Region 9 proposes to accelerate RD/RA activities at
the Operating Industries. Inc. sue by pressing for an early
settlement with the 3,500 de minimis PRPs. The Region
plans to notify the parties of liability and negotiate
remedy implementation by the end of 1993. Precedents
for size, monetary value, and time frame would be set if a
de minimis settlement of this nature could be achieved
In Region 10, a pilot is planned to improve the
quality and timeliness of PRP searches 10 address the
3
"perception of fairness" issue in enforcement activities
and settlements. The Region will make available to
Headquarters and other Regions its recommendations
for streamlining the PRP search process and wilt include
discussions on equity issues in the enforcement pro-
gram.
Regions 1,3, and 8 are also planning additional
enforcement pilots. These pilots will be described in the
next issue of this bulletin.
For further information on these pilots please
contact Ira Leigh ton in Region 1 at FTS 833-1650,
Larry Miller in Region 3 at FTS 597-3169, Richard D.
Green tn Region 4 at (404) 347-5065, Eva Hoffman in
Region 8 at (303) 293-1534, Nancy Lindsay in Region 9
at FTS 484-2421, or Carol Rushin in Region 10 at FTS
399-7151.
PRESUMPTJVE REMEDIES USED IN
THREE REGIONS TO SPEED CLEANUP
Three Regions continue work in areas that meet the
Pilot Projects Program objectives of the 30-Day Study.
Region 9 proposes the use of "plug-in" RODs to
accelerate the cleanup at a site near Phoenix. The
northern (NIBW) and southern (SIBW) sections of the
Indian Bend Wash site have similar contamination and
geology. Consequently, 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 NIBW to
quickly create new RODs for the OUs at the SIBW site.
Region 7 proposes to develop standard cleanup
goals, remedy types, ROD and Statement of Work
language, and risk assessment scenarios fa grain
storage sites, PCB sites, and coal gasification sites.
Pilot sites will be selected for application of the
standards. A process will be developed to update the
standards as science and regulations change.
Region 6 is currently piloting a project that will
shorten the Rl/FS timeframe by 75 percent at three
sites Details on this pilot are available in the March
issue of this bulleun in "Region 6 Cuts Time Between
NPL Listing and Design."
For further information on these projects, please
contact Jeff Rosenbloom at FTS 484-2362 in Region 9,
Gene Gunn at FTS 276-7776 in Region 7, and Steve
Gilrcin at FTS 255-6710 in Region 6.

-------
PILOTS THAT ARE NOT SITE SPECIFIC
BRANCH CHIEF CONFERENCE CALLS
Three regions have introduced innovative projects
that aim to improve the Superfund program in general
Region 10 plans to employ an Outreach Specialist
to impart the accomplishments of Superfund to 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 improving the quality of
data collected through the Contract Laboratory Pro-
gram. The Region is updating data protocols and
streamlining documentation, providing training to
private sector labs, and producing a guidance document
for data audits.
Additionally, Region 8 is planning a pilot that wilt
accelerate FY 1993 completions. More information
about this pilot will be available in the next ediuon of
this bulletin
For information on these projects, please call Bob
Loiselle in Region lOatFTS 399-6901, and Orteno
Villa in Region 3 at FTS 652-2299
At the May Branch Chiefs meeting in New York,
the Branch Chiefs requested that the SRO coordinate
monthly conference calls to discuss the status of pilot
projects. During (he first conference call on June 10,
the SRO presented a process for documenting and
evaluating pilot findings. Well-documented findings
are necessary to facilitate the transfer of improvements
to other sites. This process relies on monitoring teams
composed of a Regional project manager, a Headquar-
ters contact, and a Regional Counsel contact
Conference calls were also held on July 8, August
S, and September 2, during which the Regions dis-
cussed their monitoring and evaluation plans and their
experiences to date. All calls are scheduled for 4:00
p.m. EST. (The next issue of the bulletin will describe
the monitoring process in more detail.)
8 EPA Office of Solid Waste and Emergency Response
United States Environmental Protection Agency
Superfund Revitalization Office
OS-100
Washington, D.C. 20460

-------