SEPA
United States
Environmental
Protection Agency
Office of Emergency
and Remedial
Response (OERR)
EPA 540-R-01-002
OSWER 9355.0-77
March 2001
Updating Remedy
Decisions at Select
Superfund Sites
Cumulative Summary
Report
FY 1996 Through FY 1999
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
Executive Summary (FY96 - FY99)
During its first four years of implementation, Updating Remedy Decisions has been characterized by the U.S.
General Accounting Office (GAO) as one of EPA's most successful Superfund Reforms. From FY96 through
FY99, EPA updated over 300 remedies, reducing estimated future cleanup costs by more than $1.4 billion,
while at the same time increasing estimated future cleanup costs by $128.7 million. Other key successes and
findings include the following:
< Most remedy updates completed from FY96 through FY99 were the result of additional technical informa-
tion gathered as part of the remedy design process. A small number of remedy updates were the result of
non-technical changes requirements (ARARs), land use, or required cleanup levels. Another small number
of remedy updates were the result of state input or community preference, which focused on either
technical or non-technical modifications to the remedy.
< EPA tracked over 300 remedy updates from FY96 through FY99, most of which were reform-related.
• The total estimated future cost reductions (cost savings) for 64 remedy updates completed in FY96
were in excess of $350 million, of which over $325 million was based on scientific and technological
advancements.
• For 84 remedy updates completed in FY97, the total estimated cost savings were in excess of $390
million, of which over $270 million was based on scientific and technological advancements.
• For 76 remedy updates completed in FY98, the total estimated cost savings were in excess of $280
million, of which over $245 million was based on scientific and technological advancements.
• For 83 remedy updates completed in FY99, the total estimated cost savings were in excess of $430
million, of which over $420 million was based on scientific and technological advancements.
• Less than one in every 10 updated remedies resulted in an increase in estimated remedy costs.
• During this four-year period, 29 remedy updates reflected an increase in costs: no updates in FY96; five
updates in FY97 that resulted in cost increases totaling an estimated $13.5 million; 10 updates in FY98
that resulted in cost increases totaling an estimated $57.2 million; and 14 updates in FY99 that resulted
in cost increases totaling an estimated $58.0 million.
< Estimated cost savings for 206 remedy updates from FY96 through FY99 ranged from a negligible amount
to over $87 million, with most of these updates generating savings under $10 million. Estimated cost
increases for 29 individual remedy updates completed from FY96 through FY99 ranged from $10,000 to
over $44 million, with a majority under $1.5 million.
< Remedy updates generally occurred in the remedial design phase of the cleanup process and were more
likely to be documented with Explanations of Significant Differences (ESDs) than Record of Decision
(ROD) Amendments. Over the four-year period, there were 207 ESDs and 93 ROD Amendments repre-
senting remedy updates, with both cost savings and increases.
< Most remedy updates from FY96 through FY99 were initiated by parties outside EPA (e.g., potentially
responsible parties (PRPs), states, communities, federal facilities). Over the four-year period, parties
outside of EPA initiated 156 updates and EPA initiated 89 updates (these numbers do not include 62
updates initiated by more than one party). These numbers are consistent with the percentage of EPA vs.
non-EPA parties conducting cleanup work (e.g., since the inception of Superfund, the lead for remedial
design is approximately 70 percent non-EPA and 30 percent EPA).
< Over the four-year period, soil (175 updates) and ground water (129 updates) were the most common
media addressed. Another eight media types and an "other" category were also addressed by remedy
updates from FY96 through FY99. [See Exhibit 1.3 on page 5 for more details on all media types
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
affected.] This is consistent with ratios of remedies found at other Superfund sites.
In each year, the majority of ESDs and ROD Amendments took less than one year to complete.
For remedy updates completed during FY96 through FY99 in which the originally selected remedy included
a treatment component for both soil or groundwater media, EPA also selected an updated remedy that
included a treatment component at a majority of sites. [See Tables D and Eon pages 9 and 10.]
The number of remedy updates completed by each EPA region during FY96 through FY99 clearly shows
that all ten regions are implementing this reform, with most regions reporting estimated cost savings
above $50 million for the four fiscal years combined.
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
Table of Contents
Executive Summary i
1.0 Introduction 1
2.0 FY96Through FY99 Results 1
Table A: Number and Kind of Remedy Updates for FY96 Through FY99 2
Exhibit 1.1: Estimated Remedy Update Savings by Region for FY96 through FY99 3
Exhibit 1.2: Estimated Savings Per Remedy Update for FY96 Through FY99 4
Exhibit 1.3: Updates by Medium for FY96 Through FY99 5
Table B: Breakdown of Update Initiators by Fiscal Year 5
Table C: Types of Remedy Updates by Fiscal Year 6
Exhibit 1.4: Approximate Review Time for Remedy Updates for FY96 Through FY99 6
3.0 Lessons Learned 7
3.1 Reform Process 7
3.2 Benefits 7
3.3 Stakeholder Comments 7
Exhibit 1.5: Stakeholder Comments on Remedy Updates 8
4.0 Remedy Updates and Treatment 9
Table D: Comparison of Soil Remedy Updates and Treatment Components 9
Table E: Comparison of Ground Water Remedy Updates and Treatment Component 10
5.0 Conclusion 10
Acknowledgments
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
1.0 Introduction
Updating Remedy Decisions, announced in the third round of Superfund Reforms in October 1995, is one of a
broad range of administrative reforms undertaken to improve efficiency, speed, and fairness of the Superfund
program. The purpose of the Reform is to encourage the EPA Regions to revisit selected remedy decisions at
sites where significant new scientific information, technological advancements, or other considerations will be
the basis to revise remedies that protect human health and the environment while enhancing overall remedy
cost effectiveness.
This report discusses remedy updates made from FY96 through FY99. For remedy updates completed in FY96
and FY97, see the document, "Updating Remedy Decisions at Select Superfund Sites, Summary Report, FY
1996 and FY 1997," July 1998, OSWER Directive 9355.0-70. This document may be obtained on the Internet at
the EPA Superfund Reforms Website at: http://www.epa.gov/oerrpage/superfund/programs/reforms/docs/
urd96-97.pdf. The Summary Report for FY96 and FY97 contains background information on the Reform, a
description of the Reform, the process for implementing the Reform, and regional implementation plans from
each of the ten EPA Regions. For remedy updates completed in FY98 and FY99, see the document, "Updating
Remedy Decisions at Select Superfund Sites, Summary Report, FY 1998 and FY 1999,"July 2000, OSWER
Directive 9355.0-76. Additional information regarding the Reform description, status, results, stakeholder
comments, documents, and EPA contact can be obtained from the EPA Superfund Reforms website at: http://
www.epa.gov/oerrpage/superfund/programs/reforms/reforms/3-2htm.
This report:
• Provides a summary of information for those Superfund sites where remedies have been updated over the
first four years of Reform implementation;
• Highlights national and EPA regional estimated future cost reductions (cost savings) or cost increases
expected to result from implementing updated remedies; and
• Presents stakeholders with information on the role of remedy updates in improving Superfund implementa-
tion.
From the Reform's inception, EPA sought to encourage remedy updates that would incorporate new technical/
scientific information into existing site cleanups. As a whole, the administrative reforms were implemented to
make Superfund faster, fairer, and more efficient.
It is important to emphasize that this initiative does not signal any variations in the Agency's current policies
regarding site cleanup, including policies on remedy selection, treatment of principal threats, preference of
permanent remedies, establishment of cleanup levels, or the degree to which remedies must protect human
health and the environment. EPA remains committed to the protection of public health, welfare, and the environ-
ment.
2.0 FY96 through FY99 Results
More than 300 remedy updates were completed in FY96 through FY99, saving over $1.4 billion in esti-
mated site cleanup costs, while at the same time creating increases in estimated site cleanup costs of
about $128.7 million or less than 10% of the remedies reviewed.
Detailed information regarding individual remedy updates can be found in Appendices A, A.1, and A.2of the
document, "Updating Remedy Decisions at Select Superfund Sites, Summary Report, FY 1998 and FY 1999,"
July 2000 and in the document, "Updating Remedy Decisions at Select Superfund Sites, Summary Report, FY
1996 and FY 1997," July 1998. Specific remedy updates are listed by Region, and alphabetically by site name,
and include the following information:
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
• Type and date of remedy update;
• Update initiator;
• Media involved;
• State and community involvement;
• Estimated resource demands;
• Estimated cost savings or cost increases; and
• Summary of remedy change and factual basis.
Table A shows the number and kind of remedy updates that were completed during the first four years of the
Reform. (Note: In several instances, information regarding the particular kind of remedy update is either
unavailable to EPA or incomplete at the time of this writing. These are labeled NA/TBD (Not available/To be
determined)).
Table A: Number and Kind of Remedy Updates for FY96 Through FY99
FY96 FY97 FY98 FY99 Total
Total # of Updates (*)
# Updates With Est. Savings
# Updates With No Savings
# Updates With Est. Increases
# Updates NA or TBD
64
49
8
0
7
84
59
11
5
9
76
48
12
10
6
83
50
11
14
8
307
206
42
29
30
* Note: Eight remedy updates were completed in one year, but not reported until a later year. This, however,
does not significantly alter the number of updates per year. When this occurred, the update was counted only
once in the latter year.
The information in Table A shows a somewhat consistent pattern in the 4 categories - total number of updates
per year, number of updates with estimated savings, number of updates with no savings, and number of
updates where the cost changes were not available or have not yet been determined. There does appear to
be a slight increasing trend in the number of updates with estimated cost increases. The updates with
estimated cost increases occurred in seven EPA Regions (2, 3, 4, 5, 8, 9, and 10) and ranged from a mini-
mum of two to a maximum of seven updates per Region. There is no dominant Region with a higher propor-
tion of remedy updates with cost increases compared to other Regions.
Table A also shows that some remedy updates generated neither cost savings nor cost increases; however,
EPA tracked all completed remedy updates in 4 categories: 1) estimated savings, 2) estimated increases, 3)
no reported savings or increases, and 4) estimated savings or increases that could not be quantified. Since
some cost numbers have not been quantified, EPA believes that the numbers reported in Table A for both the
estimated costs savings and increases are conservative and will increase when additional costs are calcu-
lated by the party-lead for the remedy update.
Similarly, not all remedy updates were Reform-related. EPA tracked both Reform-related and non-Reform-
related updates. Reform-related updates include those based on new technical information, new science, and
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
greater advancements in technology. (See the Reform Guidance, "Superfund Reforms: Updating Remedy
Decisions," OS\NER Directive 9200.2-22, dated September 27,1996 and see also the EPA Superfund Reforms
website at http://www.epa.gov/superfund/programs/reforms/remedy/index.htm.) Non-reform-related
updates include changes in applicable relevant and appropriate requirements (ARARs), land use, or required
cleanup levels.
A breakdown of Reform- versus non-Reform-related updates demonstrates the following:
• 64 updates completed during FY96 resulted in a total estimated cost savings of over $350 million, of which
over $325 million resulted from updates of the kind identified in the Reform Guidance;
• 84 updates completed during FY97 resulted in a total estimated cost savings of over $390 million, of which
over $290 million resulted from updates of the kind identified in the Reform Guidance.
• 76 updates completed during FY98 resulted in a total estimated cost savings of over $280 million, of which
over $245 million resulted from updates of the kind identified in the Reform Guidance.
• 83 updates during FY99 resulted in a total estimated cost savings of over $430 million, of which over $420
million resulted from updates of the kind identified in the Reform Guidance.
The data over the past four years fail to show a trend in the number of remedy updates completed in a given
year, either Reform-related or not related to the Reform.
Exhibit 1.1: Estimated Remedy Update Savings by Region
for FY96 Through FY99
140
§
Over the first four years of the Reform, there were over 200 individual remedy updates that generated estimated
cost savings. The estimated cost savings per update ranged from a negligible amount to $87 million. All EPA
Regions reported savings in each year reviewed. Exhibit 1.1 shows the amount of estimated savings by Region
and by fiscal year. (Note: Exhibit 1.1 is the most complete representation of remedy updates over the past four
years; however, it may not include all remedy updates because of limitations on Regional accessibility to
remedy update information.)
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
Exhibit 1.2: Estimated Savings Per Remedy
Update for FY96 through FY99
>$10M-$20M(8%)
no savings (14%)
>$20M (6%)
>$1M-$10M(30%)
NA/TBD(10%)
:=$1M (23%)
D no savings (42)
D <=$1M(72)
• >$1M-$10M (89)
• >$10M-$20M (26)
• >$20M (19)
• NA/TBD(30)
• increases (29)
Based on 307 site;
Although there is a vast range in
remedy updates that generated cost
savings, most of these remedy
updates generated savings of less
than $10 million, as shown in Exhibit
1.2. These data were tracked
biannually and the picture found in
Exhibit 2.2 in the document "Updat-
ing Remedy Decision at Select
Superfund Sites, Summary Report,
FY1998 and FY1999, "July 2000,
for FY 1998 and FY 1999, is consis-
tent with the results contained in the
document "Updating Remedy
Decision at Select Superfund Sites,
Summary Report, FY1996 and FY
1997,"July 1998. The only category
in the FY 1998 and FY 1999 report
that shows a significant trend is the
number of remedy updates that
generated cost increases from 3 to 13 percent. This occurs because the cost increase category was not
separated into cost components similar to the multiple cost savings categories. If cost increases were sepa-
rated into multiple cost categories, a majority of remedy updates with estimated cost increases would be less
than $1.5 million.
EPA also tracked 29 individual remedy updates that generated cost increases during the first four years of the
Reform. Since there were no remedy updates completed with estimated cost increases in FY96, EPA Regions
reported remedy updates which generated cost increases during FY97 through FY99 only.
• The FY97 cost increases, which were reported for 5 remedy updates, totaled $13.5 million.
• The FY98 cost increases, which were reported for 10 remedy updates, totaled $57.2 million.
• The FY99 cost increases, which were reported for 14 remedy updates, totaled $58.0 million.
Over the past four years, there has been an increase in the number of remedy updates that generate cost
increases. The major reasons for cost increases in remedy updates are as follows: 1) identification of additional
contamination compared to what was identified in the original ROD; 2) inability of the originally selected remedy
to meet the site cleanup goals; and 3) lack of available technologies (either innovative or demonstrated) that
succeed, so that the only protective, ARAR-compliant alternative is a more costly alternative compared to the
original remedy.
Recent advances in the area of soil and ground water science and remediation made these media good candi-
dates for remedy updates. Exhibit 1.3 shows the ten most common media, as well as an "other" category.
From FY96 through FY99, updates of soil remedies were the most common remedy updates (175), followed by
ground water remedy updates (129). The data in Exhibit 1.3 do not exhibit a trend or pattern for soil or ground
water media over the four-year period. (See Section 4.0, beginning on page 9 of this report, fora comparison of
soil and ground water remedies with treatment components of original and updated remedies.)
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
Exhibit 1.3: Updates by Medium for FY96 through FY99
Medium
Soil
Ground Water
Sediment
Debris
Sludge
Leach ate
Surface Water
Other
Solid Waste
Air
Gas
FY96*
37
26
3
5
3
4
2
0
3
1
2
FY97*
39
45
8
5
2
2
4
0
3
1
0
FY98
50
31
6
9
3
1
2
4
0
1
1
FY99
49
27
11
3
3
2
1
3
0
2
2
Total
175
129
28
22
11
9
9
7
6
5
5
* Note: This information has been updated and consequently has changed marginally from that reported in
"Updating Remedy Decisions at Select Superfund Sites, Summary Report, FY1996 and FY1997, "July 1998.
The information in Exhibit 1.3 is based on 307 sites. However, since remedy updates often involve more than
one medium at a site, the total number of updates by medium is more than 307.
After soil and ground water updates, there is a substantial drop-off in the number of updates among the remain-
ing eight media and the other category. Although there are numerous fluctuations from year to year, there does
not appear to be a major increase of dropoff in a particular medium. The number of updates in Exhibit 1.3 is
consistent with media typically found at contaminated sites.
The information gathered for the Reform also tracked the initiator of the update. Table B shows the number of
updates associated with the party responsible for the update, as reported by the ten EPA Regions:
Table B: Breakdown of Update Initiators by Fiscal Year
Update Initiator
PRP
EPA
Joint (*)
Federal Facility
State
Local Gov't./Community
FY96
31
14
11
2
5
1
FY97
37
20
13
10
2
2
FY98
21
24
25
2
3
1
FY99
30
31
13
4
4
1
Total
119
89
62
18
14
5
* Note: A designation of "joint" means that more than one party began the update process. This occurs when
multiple parties review the same data at the same time and reach the same remedial conclusion.
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
Over the first four years of implementing this Reform, several variations regarding the initiator of the remedy
update were observed. Fluctuations in the number of PRP-lead and Joint-lead updates appear to be inversely
related without explanation. The data also offer little explanation for the gradual increase in the number of EPA-
lead updates and a fluctuation in the number of Federal-facility-lead updates. The two remaining categories do
not show any fluctuations.
During the first four years of implementing the Reform, EPA tracked each remedy update and its relationship to
the kind of change documenting the record. Minor or non-significant updates were documented as memos or
notes to the Administrative Record file. A significant update was documented an ESD. A fundamental update
was documented as a ROD Amendment. The following table contains the number of updates per year.
Table C: Types of Remedy Updates and Percentages by Fiscal Year
Type
ESD
ROD Amendment
Other (Note/Memo)
FY96
44 (69%)
1 7 (26%)
3 (5%)
FY97
58% (69%)
22 (26%)
4 (5%)
FY98
53(71%)
23 (29%)
0
FY99
52 (63%)
31 (37%)
0
Total
207
93
7
Table C shows only slight variations in the number of update documents per fiscal year. As mentioned above,
the type of update document selected is determined by the extent of the difference between the original remedy
and the updated remedy. In summary, most remedy updates are modifications to the originally selected remedy
and not completely new remedies.
In both the document "Updating Remedy Decision at Select Superfund Sites, Summary Report, FY1998 and
FY 7999,"July 2000, and the document "Updating Remedy Decision at Select Superfund Sites, Summary
Report, FY 1996 and FY 1997,"July 1998, EPA tracked the amount of time needed review the new site-specific
material and complete the appropriate update document. Exhibit 1.4 summarizes the approximate review time
for remedy updates completed in the first four years of the Reform.
Exhibit 1.4: Approximate Review Time for Remedy
Updates
Approximate Review Time for Remedy
Updates in FY96
,.JL
ROD-A
DESD
DOther
Based on 64 sites.
1 YEAR >l-2 >2-3
YEARS YEARS
Approximate Review Time for Remedy
Updates in FY98
Based on 76 sites.
Approximate Review Time for Remedy
Updates In FY97
..in .AJL,
ROD-A
DESD
D Other
Based on 84 sites.
<1YEAR >l-2 >2-3 >3-4 >4
YEARS YEARS YEARS YEARS
Approximate Review Time for Remedy
Updates in FY99
Based on 83 sites.
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
In each year, most of the ESDs and ROD Amendments took less than one year to complete. However, there
does appear to be an increase in the number of ESDs and ROD Amendments taking more than one year to
complete. An examination of these updates with longer review times shows that durations can be influenced by
one or more of the following: site-specific complexities, other activities that precede the update (e.g., removal or
source control action), and a protracted verification/pilot test period following discovery of new data.
3.0 Lessons Learned
Through four years of Reform implementation, EPA has gained insight into ways to successfully update site
remedies. The following sections detail some of the information collected regarding the Reform process,
Reform benefits, and comments from stakeholders.
3.1 Reform Process
The Reform process is described in Section 5.0 of the document "Updating Remedy Decision at Select
Superfund Sites, Summary Report, FY1996 and FY1997, "July 1998. The document also contains plans for
how each EPA Region intended to implement the Reform. EPA has not significantly changed the remedy
update process since its inception and the issuance of the Reform Guidance document, "Superfund Reforms:
Updating Remedy Decisions," OSWER Directive 9200.2-22, dated September 27,1996. This continuity is
demonstrated by the consistency of slight increases in the number of remedy updates and estimated cost
savings over the first four years of Reform implementation. All ten EPA Regions have shown continued support
and participation in implementing this Reform and continue to adhere to their implementation plans announced
in 1997. The Reform process continues to function as intended and the results of the first four years do not
suggest a need for a significant change.
3.2 Benefits
This Reform has been very successful in bringing past Superfund site decision-making in line with current
science and technology. By doing so, these updates improve the cost effectiveness of site remediation while
ensuring reliable short- and long-term protection of human health and the environment. The quantifiable results
of this Reform have been announced in EPA's testimony before Congress, private industry evaluations of
Superfund reforms, and a report of the GAO. Of additional note is EPA's overwhelmingly positive record of
responding to remedy update requests made by outside parties.
Over the first four years of this Reform, there were many examples of updates based on new technology, new
performance data, coordination among numerous parties, input from States and the public, calculations of
money saved or additional resources needed, and quick turn-around time in completing the update. (See
Section 4.2 in the document, "Updating Remedy Decision at Select Superfund Sites, Summary Report, FY
7 998 and FY 7999, "July 2000, and Section 6.2 of the document "Updating Remedy Decision at Select
Superfund Sites, Summary Report, FY 1996 and FY 1997,"July 1998.)
3.3 Stakeholder Comments
During the first four years of this Reform, EPA received much positive feedback from other government agen-
cies and outside parties. Of note is the May 2000 U.S. General Accounting Office Report to Congressional
Requesters titled, "Superfund, Extent to Which Most Reforms Have Improved the Program is Unknown," (GAO/
RCED-00-118). In this report, GAO notes that this Reform has several measurable goals, outcomes, and
outputs. Several observations from GAO and various stakeholders are contained in Exhibit 1.5.
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
Exhibit 1.5: Stakeholder Comments on Remedy Updates*
Sustained Effects:
• EPA's data show that the regions are updating remedy decisions and achieving cost savings for both
responsible parties and EPA.
• EPA predicts that at some point in the future, the regions will have reviewed most past remedies for an
update and the opportunities to achieve additional cost savings will decrease.
Contribution of Other Factors:
• EPA acknowledges that other reforms addressing remedy selection, such as the directive providing
more flexibility to assume that a site will be used for industrial rather than residential purposes and will
therefore require less extensive cleanup, also deserve credit for contributing to the cost savings
achieved.
Regional Implementation:
• Some industry representatives said that individual cleanup managers and regions differ in their willing-
ness to consider a remedy for an update; as a result, the representatives believe they do not have a
consistent opportunity to achieve cost savings.
• ...EPA's data show regional differences in the number of updates conduced-one region updated three
times as many remedies as another...both regions managed about the same number of Superfund sites.
• EPA did not determine the reasons for the differences, but reform managers suggested that there could
be a valid reason for them. For example, one region could have more sites with contaminated ground
water-a type of site that would be a good candidate for a remedy update because new cleanup technolo-
gies have become available.
Performance Measurement:
• ...EPA admits that its estimates of cost savings are not rigorous, partly because the agency depends
on private parties to provide estimates of cost savings for the cleanups they manage.
• ...EPA (1) does not maintain supporting documentation for the savings estimates, and (2) cannot require
private parties to provide such documentation.
Views on the Reform's Benefits/Effectiveness:
• Industry representatives gave high marks to this reform for leading to more cost-effective cleanups.
*These comments are excerpted form Appendix 1 of the report, "Superfund: Extent to Which Most Reforms
have Improved the Program is Unknown, "published in May 2000 by the General Accounting Office.
"There was great fear when EPA in 1995 announced its plans to review prior decisions on remedy selection.
Some expected that nothing would change. Others feared the floodgates had been opened. What followed
instead was an orderly and sound process. It involved a minority of sites where remedial action was under-
way, but at many of those sites changes were made that sharply reduced total costs without sacrifice of
environmental protection."**
**Excerpted from "The Superfund Program At Its 20th Anniversary: Achievements of the Past, Challenges
for the Future", Comments by the Superfund Settlements Project, December 11, 2000.
"EPA has instituted a number of procedures to make sure that the best, and most up-to-date, information is
used in deciding a cleanup remedy. These reviews continue even after a cleanup has started."***
***Excerpted from "Superfund: 20 Years of Protecting Human Health and the Environment", December 11,
2000.
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
4.0 Remedy Updates and Treatment
CERCLA Section 104 and Section 300.430 of the National Contingency Plan (NCR), revised in 1990, require
that each remedial action apply permanent solutions and alternative treatment technologies or resource recov-
ery technologies to the maximum extent practicable. The NCR also states that, as part of the best balancing of
trade-offs among alternatives, EPA shall consider the preference for treatment as a principal element and the
bias against off-site land disposal of untreated waste. While Reviewing the information contained in remedy
updates during the first four years of implementation, EPA evaluated the continued use of treatment in the
original remedy compared to the updated remedy. The following two tables summarize the update information
reported for the two most common media - soil and ground water:
Table D: Comparison of Soil Remedy Updates and Treatment Components
(1)
(2)
Year # of reviews
with a soil
component
(3)
# of reviews with treatment
for soil component in the
original remedy
(4)
(5)
# of updates with # of updates with no
whole or partial soil soil treatment (e.g.,
treatment component containment only) in
in the updated remedy the updated remedy*
1996
1997
1998
1999
Total
37
39
50
49
175
27
26
32
26
111
17 (63%)
12 (46%)
22 (69%)
18 (69%)
69 (62%)
10 (37%)
14 (54%)
10(31%)
8(31%)
42 (38%)
* Note: This category includes soil remedies that went from on-site treatment to off-site disposal with no
mention of treatment prior to disposal. Some updated soil remedies may have, in fact, treated before disposal
so that these numbers overestimate the use of no treatment.
Table D shows that over the first four years of the Reform there were 175 remedy updates with a soil component
(Column 2) and, of these, 111 soil remedies included at least one treatment component in the original soil
remedy (Column 3). Columns 4 and 5 compare treatment of the updated soil remedy to the original soil remedy.
In the majority of updates with a soil component, approximately 62 percent, there is at least one treatment
component in the updated soil remedy. This demonstrates that EPA's remedy updates continue to reflect a
preference for treatment as a principal element of the soil remedy.
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
Table E: Comparison of Ground Water (GW) Remedy Updates and Treatment Components
(1)
(2)
(3)
(4)
(5)
(6)
Year # of reviews # of reviews with # of updates with # of updates with # of updates that
with a GW treatment for whole or partial no GW treatment went from GW
component
GW component
in the original
remedv
GW treatment or containment treatment to
component in the component in the monitored natural
updated remedy updated remedy
attenuation
1996
1997
1998
1999
Total
26
45
31
27
129
18
34
24
18
94
12 (67%)
22 (64%)
15 (62%)
10 (56%)
59 (63%)
5 (28%)
6 (18%)
5 (21%)
2(11%)
18(19%)
1 (5%)
6 (18%)
4(17%)
6 (33%)
17(18%)
TaWeE shows that over the first four years of the Reform, there were 129 remedy reviews with a ground water
component (Column 2) and, of these, 94 were ground water remedies which included at least one treatment
component in the original remedy (Column 3). Columns 4 and 5 compare treatment of the updated ground water
remedy to the original ground water remedy. In the majority of updates with a ground water component, approxi-
mately 63 percent, there is at least one treatment component in the updated ground water remedy. This fact
demonstrates that EPA's remedy updates continue to reflect a preference for treatment as a principal element of
the ground water remedy. Table E also shows an increase in the frequency of updating ground water treatment
remedies to monitored natural attenuation (MNA) remedies (Column 6). For purposes of this discussion, MNA
has been separated from treatment methods. However, just as required of treatment remedies, MNA still needs
to meet cleanup goals and cleanup levels in a reasonable time frame. The data show a significant percentage
increase over time in the use of MNA. MNA tends to be used at most sites as a response action for the least
contaminated portion of the contaminated plume and as a finishing step after active treatment or a source
control response has been completed.
5.0 Conclusion
Generally, both EPA and outside parties consider Updating Remedy Decisions a successful Superfund Reform
from FY96 through FY99. The number of remedy updates completed by each EPA Region during each fiscal
year clearly shows that all ten Regions are implementing this reform, with most Regions reporting estimated
cost savings above $50 million for the four fiscal years combined. All ten Regions continue to evaluate re-
quests to review old Fund-lead remedies, as well as consider updates to more recent remedies that may not be
up-to-date with current science or technology. Regions also continue to encourage outside parties to submit
remedy update requests to EPA when new technical information exists to support them. For the most part,
EPA and outside parties share the benefits of both cost and time savings as part of implementing the updated
remedy.
Interested parties should review the existing Reform Guidance (OSWER Directive 9200.2-22) for basic informa-
tion concerning the Reform. Additional guidance on remedy updates is included in the updated Record of
Decision Guidance (see "A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other
Remedy Selection Decision Documents," OSWER Directive 9200.1-23P, July 1999). Specific questions on
implementation of this reform may be directed to Matt Charsky of the Office of Emergency and Remedial
Response by telephone at (703) 603-8777, e-mail at charsky.matthew@epa.gov, or FAX at (703) 603-9133.
Each Region also has a remedy update contact who can be accessed by contacting the Superfund Program
area in any of EPA's ten regional offices.
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CUMULATIVE SUMMARY REPORT FY96 THROUGH FY99
Acknowledgments
This report was made possible by the dedicated efforts of numerous EPA Superfund staff. Regional remedial
project managers (RPMs) responsible for considering and implementing remedy updates at Superfund sites are
to be commended for making these changes to select the best technologies available at Superfund sites
nationwide.
This report was prepared for EPA under contract #68-W6-0038.
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