EPA540-R-98-025
United States Solid Waste and OSWER9205.5-15A
Environmental Protection Emergency Response PB98-963 233
Agency (5305W) June 1998
RCRA, Superfund & EPCRA
Hotline Training Module
Introduction to:
Superfund Accelerated
Cleanup Model
Updated February 1998
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DISCLAIMER
This document was developed by Booz-Allen & Hamilton Inc. under contract 68-WO-0039 to EPA. It is
intended to be used as a training tool for Hotline specialists and does not represent a statement of EPA
policy.
The information in this document is not by any means a complete representation of EPA's regulations or
policies. This document is used only in the capacity of the Hotline training and is not used as a reference
tool on Hotline calls. The Hotline revises and updates this document as regulatory program areas change.
The information in this document may not necessarily reflect the current position of the Agency. This
document is not intended and cannot be relied upon to create any rights, substantive or procedural,
enforceable by any party in litigation with the United States.
RCRA, Superfund & EPCRA Hotline Phone Numbers:
National toll-free (outside of DC area) (800) 424-9346
Local number (within DC area) (703) 412-9810
National toll-free for the hearing impaired (TDD) (800) 553-7672
The Hotline is open from 9 am to 6 pm Eastern Time,
Monday through Friday, except for federal holidays.
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SUPERFUND ACCELERATED CLEANUP MODEL
CONTENTS
1. Introduction 1
2. Elements of SACM 5
2.1 Site Assessments 5
2.2 Early and Long-term Actions 6
2.3 Enforcement 8
2.4 Public Participation 9
2.5 Regional Decision Teams 9
3. Presumptive Remedies and Response Strategies 11
4. Module Summary 15
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SACM -1
1. INTRODUCTION
The Superfund program has been both praised and criticized for how it addresses
abandoned hazardous waste sites. One of the most effective parts of the program is
the CERCLA statutory enforcement provisions that force polluters to pay. On the
other hand, one of the major criticisms has been that site assessments, response
actions, and enforcement have been costly and slow. In 1980, when CERCLA was
enacted, Congress did not anticipate the number of uncontrolled hazardous waste
sites that actually exist. With reauthorization in 1986, Congress amended CERCLA
enhancing the response process, enforcement provisions, public participation
provisions, and increasing the appropriations to 8.5 billion dollars to meet the needs
of the program. Several factors that drove costs up at Superfund sites include
extended site assessments with duplicative sampling efforts, litigation with
potentially responsible parties (PRPs), and lengthy remedy selection analyses. These
factors, as well as others, contribute to the public's perception that the Superfund
program was inefficient. In April 1992, EPA responded to these shortcomings by
introducing the Superfund Accelerated Cleanup Model (SACM). SACM streamlines
the traditional Superfund response process that was established by Congress in
CERCLA, as amended by SARA. SACM does not change the regulations for the
traditional site evaluation process, but rather makes administrative changes to the
traditional approach, while remaining consistent with existing response regulations
outlined in the National Contingency Plan (NCP).
The main goals of SACM are:
• Non-duplicative site assessment
• Prompt risk reduction
• Cross-program coordination of response planning
• Early initiation of enforcement activities
• Early public notification and participation.
After successfully implementing the SACM process at several pilot sites, EPA
announced its expectations to use SACM at all Superfund sites (OSWER Directive
9203.1-13).
In addition to SACM, EPA is developing other tools, such as presumptive remedies
and response strategies, to speed up the response process. Presumptive remedies are
used for sites with similar conditions and contamination. These presumptive
remedies are technologies that have been selected repeatedly at a preponderance of
certain types of Superfund sites. For instance, certain technologies have been
consistently selected during the past decade for wood preserving facilities; therefore,
instead of following a lengthy remedy selection process for each site, the lead agency
may decide to examine just a few of the pre-designated presumptive remedies for
wood preserving facilities. Presumptive response strategies are more
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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2 -SACM
comprehensive than presumptive remedies in that they address all components of
the response process, rather than just the remedy selection.
This module presents the primary aspects of SACM compared to the traditional
Superfund response process. These two approaches to the Superfund response
process are illustrated in Figure 1. In addition, this module discusses presumptive
remedies by covering what they are, and providing an overview of the guidance
EPA has developed.
After you have completed this module, you should be able to:
• Explain how SACM streamlines the traditional response process
• Be familiar with the terms of the response process as renamed by SACM
• Explain what presumptive remedies are and provide examples.
Use this list of objectives to check your knowledge after the training session on
SACM and presumptive remedies.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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SACM - 3
Figure 1
THE TRADITIONAL SUPERFUND PROCESS VS. THE SACM PROCESS
Curent Superfund
Process
Superfund Accelerated
Cleanup Model (SACM)
Site
Discovery
I
Preliminary Assessment (PA)
Site Assessment (SI)*
Expanded Site Inspection (ESI)
I
Hazard Ranking System (MRS)
National Priorities List (NPL)
Site Screening &
Assesssment
(PA, SI, ESI, Rl)
Enforcement
Activites/
State
Participation/
Community
Relations
I
Remedial Investigation (Rl)
Feasibility Study (FS)*
I
Selection of Remedy/
Record of Decision (ROD)
Long-
Term
Hazard
Ranking
Remedial Design
(RD)
Remedial Action
(RA)
i
Operation and
Maintanance (O&M)
I
NPL
Deletion
Enforcement
Activites/
State
Participation/
Community
Relations
£
Long-
Term
Action
Long-
Term
Action
Complete
* indicates assessment phase of
pipeline
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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4 -SACM
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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SACM - 5
2. ELEMENTS OF SACM
To streamline the traditional Superfund approach, SACM reorganizes and
restructures various components of the response process. In particular, SACM
integrates the numerous Superfund site assessments to create a single, more
efficient evaluation. SACM also redefines the traditional removal and remedial
actions as early actions and long-term actions, thereby achieving quicker risk
reduction and a more effective, final site cleanup. EPA also continues to highlight
rapid enforcement actions and a high level of public participation as an integral part
of SACM. To oversee effective implementation of its new approach, SACM uses the
expertise of Regional Decision Teams (RDTs). This section further describes these
key aspects of SACM.
2.1 SITE ASSESSMENT
Prior to SACM, Superfund site evaluations followed a series of discrete, redundant
steps. EPA often performed evaluations under the removal program (preliminary
assessments (PAs), and site inspections (Sis)), and the remedial program (PAs, Sis,
Hazard Ranking System scores (HRS), remedial investigations (RIs)) separately,
without considering information gathered under preceding evaluations. Thus, each
evaluation potentially required separate contracts, equipment, sampling teams,
sampling strategies, and health and safety plans. This resulted in inefficient use of
time and money that reflected negatively on the program in the eyes of both
Congress and the public.
SACM accelerates the response process by integrating evaluations using both
removal and remedial authority. Before beginning an assessment, EPA predicts the
data needs based on the expected response. For example, if EPA believes the
contamination is extensive enough to warrant a site's inclusion on the NPL, data
can be collected simultaneously for the HRS (to determine if the site will be placed
on the NPL) and for the RI/FS (to select an appropriate remedy). If possible, one
continuous site evaluation with one report is conducted at each site (OSWER
Directive 9203.1-03). For more guidance on site assessment and the SACM process,
refer to Assessing Sites Under SACM — Interim Guidance (OSWER Directive
9203.1-051).
The following fictional examples provide an illustration of the traditional site
assessment versus the SACM integrated assessment.
Example la: Traditional Superfund Site Assessment:
EPA receives a public request to assess an old chemical manufacturing facility
containing thousands of leaking barrels in an unlined lagoon. A contractor
performs a removal PA and the site is placed in CERCLIS. The contractor then
conducts a removal SI to determine the need for a removal. The SI confirms
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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6 -SACM
that the soil and water are extremely contaminated, and EPA removes the barrels
to minimize immediate threats. A year after completion of the removal, EPA
initiates the remedial SI and begins to collect data for the HRS. The site is placed
on the NPL and the RI/FS begins. Three years later, after completion of the
RI/FS, remedy selection, and remedial design, EPA initiates the remedy. Five
years have elapsed from discovery of the site to implementation of the remedy.
Example Ib: SACM Integrated Site Assessment:
EPA receives a public request to assess the same chemical manufacturing facility.
After initial data gathering, the Agency believes the contamination will warrant
the site's inclusion on the NPL. A contractor collects data to determine whether
a removal action is necessary, to calculate the HRS score, and to select a remedy.
The CERCLA and NCP requirements for the removal and remedial PA and SI,
the HRS ranking, and the RI/FS are all met in a single site evaluation with a
single report. The barrels are removed, the site is placed on the NPL, and the
remedial action begins. Two and a half years have elapsed from the site's
discovery to implementation of the remedy.
The integration of the various site evaluations under the two programs, and the
anticipation of the site's NPL listing, reduced the cost and duration of the response
by two and a half years.
2.2 EARLY AND LONG-TERM ACTIONS
Since CERCLA created only two response authorities, remedial and removal, two
separate cleanup programs evolved. Because all Superfund cleanup actions are
required to use one of these authorities, EPA placed all sites into one of the two
programs and the programs operated separately. SACM, instead of directing sites
under one of the removal or remedial programs, uses both authorities together to
conduct early and long-term actions.
EARLY ACTIONS
The duration of an early action should generally be less than five years. The goal of
an early action is to quickly reduce threats to human health and the environment.
This may require that more than one early action be taken at some sites. An early
action operates under either removal or remedial authority. Emergency removals,
time-critical responses, and non-time-critical responses are early actions taken under
removal authority. Early remedial actions are performed under remedial authority.
Depending on the type of action, different statutory and regulatory requirements
must be met for Fund-lead sites. For instance, except in special circumstances,
removal authority can only be used for actions requiring less than 2 million dollars
and 12 months. State assurances, a record of decision (ROD), and identification of
applicable or relevant and appropriate requirements (ARARs) are required for early
remedial actions, just as they are for traditional remedial actions. An early action
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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SACM - 7
can occur in conjunction with a long-term action at a site. This is referred to as a
"phased approach" and ensures a site is cleaned up as quickly and effectively as
possible. Examples of early actions are given in Figure 2.
LONG-TERM ACTIONS
EPA expects long-term actions to take longer than five years to complete. They may
occur at sites where high remedy implementation costs exist, or when long-term
operation and maintenance activities (e.g., groundwater monitoring) are necessary.
Long-term actions follow the NCP remedial process requirements, including NPL
listing, a RI/FS, and a ROD. Examples of long-term actions are given in Figure 2.
For more information on both early and long-term actions see Early Action and
Long-term Action Under SACM - Interim Guidance (OSWER Directive 9203.1-051).
Figure 2
TYPES OF EARLY AND LONG-TERM ACTIONS
Early Action
Either
Long-Term Action
Access Restrictions
Source Removals
Source Containment
Surface Structures
Source Remediation
Capping/Containment
Relocation
Source Extraction
Alternate Water Supply
Property Acquisition
Groundwater Plume Cleanup
Plume Containment
Extensive Source Remediation
Groundwater Restoration
Surface Water Restoration
The following fictional examples illustrate how early actions and long-term actions
require less time and resources than traditional removal and remedial actions.
Example 2a: Traditional Response Process:
A work crew discovers a small (e.g., three-acre) abandoned landfill while
constructing an apartment complex in a residential area where the community
relies on groundwater as its primary source of drinking water. A removal PA/SI
determines that, to reduce immediate threats, the contaminated soil must be
excavated and removed. Further, to prevent contaminated groundwater from
reaching nearby drinking water aquifers, the removal contractor installs three
extraction wells. Later in the remedial SI, EPA personnel decide to collect data
for an HRS score, as well as for the RI/FS to select a long-term remedy. As part of
this remedy, a second contractor excavates an additional, deeper layer of soil to
eliminate the source of contamination. During the RI, EPA determines that the
extraction wells installed under the removal program did not meet all ARARs,
and were not situated to extract the entire plume of contaminated groundwater.
The remedial contractor therefore installs four more wells, for a total of seven.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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8 -SACM
The contaminated groundwater plume is extracted and treated and the aquifer is
returned to its beneficial use.
Example 2b: SACM Process:
At the same site, an integrated site assessment provides HRS and RI/FS data, and
helps EPA determine that it must remove the surface layer of contaminated soil
under time-critical authority, and a deeper layer of contaminated soil with an
early remedial action. One contractor simultaneously removes both of these
layers. Also, as a removal action, the contractor drills three extraction wells to
protect the drinking water sources. The wells meet all ARARs and are
strategically placed such that only one more well is needed for the long-term
remedial action. These four wells extract the contaminated groundwater plume,
and the aquifer returns to its beneficial use.
In this scenario, EPA used removal and remedial authorities together to consolidate
steps in the cleanup process and provide an equal measure of protection and
remediation. A more efficient remedial design saved time and money.
2.3 ENFORCEMENT
SACM continues to emphasize EPA's "enforcement first" policy. Thus, EPA must
initiate potentially responsible party (PRP) searches and negotiations as early as
possible. However, because response actions under SACM may begin sooner, there
is a greater need to expedite PRP searches so that response actions may begin. To
preserve valuable resources, Regions must be careful to expedite PRP searches only
at sites that may need a remedial response. Thus, the timing of searches is very
important, and EPA must have a clear strategy to conduct PRP searches.
In order to conduct PRP searches more quickly, SACM encourages the use of a
phased PRP search that focuses on establishing the liability of, and negotiating with,
those PRPs who are easily found. Once EPA identifies the core group of PRPs, the
PRPs can lead the response, with EPA oversight. Involvement with PRPs whose
liability is too costly or time-consuming (e.g., extensive litigation is necessary) to
establish may be delayed until after initiation of the response action.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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SACM - 9
2.4 PUBLIC PARTICIPATION
EPA's experience has shown that early and frequent communication with local
communities can enhance a site response; this is particularly true under SACM.
Because SACM is a new and unfamiliar approach to cleanup, public outreach and
education are crucial to obtaining public support. EPA must continue to involve
the public as early as possible throughout all stages of the response process.
Integrated site assessments and early actions, however, may have community
involvement requirements that differ from traditional requirements. For example,
because the NCP requires that the administrative record be made available when the
RI/FS begins, a site undergoing a combined SI/RI/FS will require earlier
establishment of an administrative record.
2.5 REGIONAL DECISION TEAMS
If SACM is to successfully decrease the time and money spent under the Superfund
program, a creative and informed approach is needed for each site. To ensure solid
decisions are made, an experienced and knowledgeable team of experts, typically
called a Regional Decision Team (RDT), has been formed in many of the Regions.
The goals of the RDT are effective coordination, communication, and integration of
program authority, expertise, and resources to implement wise and consistent
decisions at Superfund sites.
Regions have flexibility both in establishing and selecting the members of the RDT.
Some Regions may have more than one team while some may not establish a RDT
as a method to implement SACM. Members may include state officials, on-scene-
coordinators (OSCs), remedial project managers (RPMs), community involvement
coordinators, and site and risk assessors. Once selected, the RDT develops rules that
apply to all sites in the Region including criteria for selecting response actions and
PRP search methods. Strategies for communicating with Headquarters, states, and
support agencies, such as the Department of Justice, are created, and a plan for
integrating site evaluations is formed.
Although the day-to-day operations of each site remain the responsibility of the site
managers, the RDT can play a major role in site-specific decisions. The Team
prioritizes sites in the Region by addressing the worst sites first, and decides how
early and long-term actions should be used at each site. The RDT may provide
policy and strategic direction to site managers, sign RODs or action memoranda, and
determine which sites are of NPL caliber so the RI/FS can be included in the
integrated site assessment. In addition, the RDT ensures that response actions are
fully consistent with the requirements contained in CERCLA and the NCP. For
more information on SACM's RDT mechanism see SACM Regional Decision
Teams - Interim Guidance (OSWER Directive 9203.1-051)
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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10 -SACM
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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SACM- 11
3. PRESUMPTIVE REMEDIES AND RESPONSE STRATEGIES
Presumptive remedies are a key component of SACM. They represent a way to
streamline remedy selection based on experience at certain types of sites. Before
SACM, EPA presumed that each site on the NPL was unique and required a site-
specific review of remedial alternatives. EPA has now learned from experience that
many sites have similar contaminated media, types of wastes, or historical
industrial practices, and as a result, will most likely require use of similar
technologies in the remedy. By adopting technologies consistently selected at the
majority of similar sites, presumptive remedies ensure that a site is cleaned up
faster, while still remaining consistent with the NCP's intent of protecting human
health and the environment. Also, since the Agency anticipates using presumptive
remedies at appropriate sites, remedy selection is expected to be generally more
consistent across the nation.
EPA identified several categories of sites where presumptive remedies are
appropriate: municipal solid waste landfills (MSWLFs); sites with volatile organic
compounds (VOCs) in soils, sediments, and sludges; and woodtreater sites.
Presumptive remedy guidance exists for all of these types of sites and is under
development for sites with metal contamination.
For certain types of sites or contaminants, EPA believes a broader approach, a
"comprehensive response strategy," is more appropriate. To date, only a
presumptive response strategy for sites with groundwater has been developed. EPA
is currently contemplating a comprehensive response strategy for manufactured gas
plant (MGP) sites. The discussion below provides details of existing and future
presumptive remedies.
MUNICIPAL SOLID WASTE LANDFILLS
In September 1993, EPA selected a presumptive remedy for MSWLFs, which
constitute approximately 20 percent of all NPL sites (OSWER Directive 9355.3-18FS).
Because treatment is usually impracticable at such sites, the presumptive remedy is
a containment remedy which includes the following components as appropriate on
a site-specific basis: capping to contain the contamination, collection and treatment
of the gas and leachate, containment of the contaminated groundwater plume, and
the use of institutional controls to supplement engineering controls. Since all of
these actions are demonstrated methods of reducing the risk at MSWLFs, they are
now a part of a multi-component presumptive remedy for MSWLFs.
The containment presumptive remedy also takes into account the possibility that
hot spots, e.g., drums containing principal threat wastes, may need to be addressed.
EPA decides whether the combination of the waste's physical and chemical
characteristics and volume is such that the integrity of the new containment system
will be threatened if the waste is left in place. If so, the hot spot may need to be
The Information In this document Is not by any means a complete representation of EPA's regulations or policies,
but Is an Introduction used for Hotline training purposes.
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12 -SACM
treated or excavated prior to construction of the landfill cap. This presumptive
remedy does not address exposure pathways outside the landfill, and does not
provide a long-term remedy for groundwater restoration. More guidance on the
presumptive remedy for municipal waste landfills is found in Presumptive Remedy
for CERCLA Municipal Waste Landfill Sites (OSWER Directive 9355.0-49FS).
SITES WITH VOCs IN SOILS
Over the years, EPA conducted numerous remedial actions at sites with VOC
contamination. This wealth of experience allowed EPA in September 1993, to
identify three preferred technologies based on a comprehensive ROD analysis.
These treatment methods - soil vapor extraction, thermal desorption, and
incineration of the contaminated soil - comprise the presumptive remedy for sites
with VOC contamination. The first remedy, soil vapor extraction, removes VOCs by
passing air through the soil. Thermal desorption heats the soil until the VOCs are
vaporized and collected for treatment. Incineration decomposes VOCs at high
temperatures. Except under unusual circumstances, one of these remedies should
be used at a site with VOC contamination. More information on this presumptive
remedy is found in Presumptive Remedies: Site Characterization and Technology
Selection for CERCLA Sites with Volatile Organic Compounds in Soils (OSWER
Directive 9355.0-48FS).
WOOD TREATER SITES
As EPA gained experience at sites contaminated by wood treatment processes, four
treatment technologies emerged as the most frequently selected. The Agency
selected these technologies as the presumptive remedies for wood treater sites in
December 1995. Three of the technologies are for treatment of organic
contaminants, and one is for treatment of inorganic contaminants. If organic
contaminants are present at the site, bioremediation, which is the chemical
degradation of organic contaminants using microorganisms, is the primary remedy.
Thermal desorption or incineration are also options for treatment of organic
contaminants. The presumptive remedy for wood treater sites with inorganic
contamination is immobilization. Immobilization traps the chemical in place,
either by solidifying it (e.g., with a cement), or stabilizing it (i.e., chemically binding
it to its surroundings). Sites with both organic and inorganic contamination use a
series of organic and inorganic treatments called a treatment train. For more
guidance on wood treater sites, see Presumptive Remedies for Soils. Sediments, and
Sludges at Wood Treater Sites (OSWER Directive 9200.5-162).
GROUNDWATER CONTAMINATION
Initially, EPA did not anticipate the extent and types of groundwater contamination,
nor the complexity of subsurface conditions found at Superfund sites. Since
approximately 85 percent of Superfund sites have contaminated groundwater, EPA
decided it necessary to create a remedy selection guidance. Because of the complexity
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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SACM - 13
of these sites, there is no single technology that is appropriate for all sites with
groundwater contamination. Therefore, in October 1996, EPA created a presumptive
response strategy instead of a presumptive remedy. Because it is difficult and time-
consuming to fully characterize the subsurface nature of a site, a recurring problem
at groundwater contaminated sites was that remedies were selected without
sufficient data. Thus, a major part of the presumptive strategy is the phased
approach, which allows data collected from initial assessment phases to be used to
further characterize the site. Thus, the remedy is selected using more accurate and
complete information. EPA also outlined methods for deferring the selection of, or
refining, a remedy after the ROD is signed. Finally, the Agency selected several
presumptive technologies for treatment of extracted groundwater. See Presumptive
Response Strategy and Ex-Situ Treatment Technologies For Contaminated Ground
Water at CERCLA Sites (OSWER Directive 9283.1-12) for more guidance.
FUTURE PRESUMPTIVE REMEDIES AND RESPONSE STRATEGIES
Only the metals in soils presumptive remedy remains to be completed. EPA
considered developing additional presumptive remedies, including one for sites
with PCB contamination, but found remedies for those other categories of sites
already stipulated through other program regulations; thus no new presumptive
remedies are currently anticipated. The current focus for this initiative is on
appropriately using existing presumptive remedies. EPA's Technology Innovation
Office is currently developing a presumptive response strategy for manufactured gas
plant sites.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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14 -SACM
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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SACM - 15
4. MODULE SUMMARY
EPA created SACM to reduce the time and money spent at Superfund sites, while
continuing to protect human health and the environment. Instead of conducting a
series of separate site assessments, SACM integrates them into one continuous site
assessment with one report, if possible. Also, where EPA once categorized all
actions as either remedial or removal, the Agency now conducts early and long-
term actions using either authority. This allows for earlier remedial actions and
earlier risk reduction. EPA continues to use an enforcement first policy, and
attempts to begin enforcement procedures as soon as possible under SACM. Public
perception of SACM is a high priority, thus the involvement of the public at all
stages of the response is absolutely necessary.
The SACM process is coordinated by RDTs comprised of EPA and state personnel
experienced in early and long-term actions, site assessment, enforcement, and
community relations.
The presumptive remedy initiative under SACM promotes the use of cleanup
technologies historically shown to be effective at similar types of sites. To date, EPA
has published presumptive remedies for municipal landfills, sites with VOC
contamination, and wood treater sites, as well as a presumptive response strategy for
groundwater contamination.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction used for Hotline training purposes.
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